The King v. Proud

The King v. Proud

Where a claimant lived openly with the insured as his wife, had children acknowledged by him as legitimate, was accepted by reputable people as his wife and the insured himself treated her as his wife, those facts constitute prima facie proof of marriage sufficient to uphold entitlement under the Returned Soldiers'...

Source-derived case information.

Citation
[1926] SCR 599
Parties
Appellant (crown): His Majesty The King; Respondent (suppliant): Elsie Proud
Court
Supreme Court of Canada
Jurisdiction
Canada
Judgment Date
4 May 1926
Procedural Posture
Appeal; Petition of Right Under the Returned Soldiers' Insurance Act / On Appeal to the Supreme Court of Canada From the Exchequer Court of Canada; Final Determination
Outcome
Appeal dismissed; judgment of the Exchequer Court affirmed.
Legal Topics
Proof of Marriage, Beneficiary Entitlement Under Statutory Insurance, Prima Facie Evidence, Cohabitation and Reputation
Source Language
english
Family Law Insurance Law Evidence Law Proof of Marriage Beneficiary Entitlement Under Statutory Insurance Prima Facie Evidence Cohabitation and Reputation

Source-derived case record

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Parties

His Majesty The King

Appellant (crown)

Elsie Proud

Respondent (suppliant)

Procedural Posture

Appeal; Petition of Right Under the Returned Soldiers' Insurance Act / On Appeal to the Supreme Court of Canada From the Exchequer Court of Canada; Final Determination

  1. 1 Whether claimant established a valid marriage for beneficiary status under the Returned Soldiers' Insurance Act
  2. 2 Whether absence of a marriage certificate or detailed recollection defeats entitlement
  3. 3 What weight cohabitation, acknowledgment of children and community reputation carry as evidence of marriage

Ratio Decidendi

Where a claimant lived openly with the insured as his wife, had children acknowledged by him as legitimate, was accepted by reputable people as his wife and the insured himself treated her as his wife, those facts constitute prima facie proof of marriage sufficient to uphold entitlement under the Returned Soldiers' Insurance Act despite absence of a marriage certificate or detailed recollection of the ceremony; the trial judge's acceptance of such evidence must be affirmed.

Court Disposition

Appeal dismissed; judgment of the Exchequer Court affirmed.

Orders

  • Appeal dismissed with costs
  • Judgment of the Exchequer Court affirmed