alex,
Yes, to the city hall in Japan I took the original UK marriage certificate and its Japanese translation (done by me), and they had a fat file with a lot of marriage certificate formats from different countries (and cities) - they checked my certificate against the "sample" they had, so to say, and confirmed it was valid, then it was accepted, and my marriage to my EU spouse was entered as "AK married to Mr So-and-so dated (the UK marriage date) according to the UK law, and it was reported to XX city on (date when I reported)" onto my family register. So the Japanese authorities "officially" accepts UK marriages as valid. They do have the system to do that.
So.... I understood the British consulate's comments as they don't have the system to do the reverse (of what I did), meaning, accepting marriages conducted outside the UK. Strange that they do not mention whether Japanese marriages are even considered valid in the UK or not :(
Well, to be honest, I have a faint idea (at least one reason) why the UK might not want to accept Japanese marriages - the ease of divorces (Japanese laws do not require a family court decision or even a long-term separation for a divorce). This "ease" might make Japanese marriages something like a Reno marriage, and might be one reason why UK does not consider Japanese marriages not quite right. But you see, this is nothing they would want to express their views upon on the UK embassy/consulate general website... So instead they say contact a lawyer in the UK, I assume.
I know a few japanese who got married in Japan or Guam. Presumably they did the same thing: completed the marriage paperwork in japan and then "got married again" in Hawai .
I know several Japanese couples who got married in Japan (= paperwork, the legal bit) then went to Hawaii or Guam and did the church ceremony in style there, but the church ceremony in the US was not a "legal" wedding (this was just for the ceremony), so their marriage is based on the Japanese law. It was no double marriage.
On the other hand, I know another Japanese couple who actually wanted to have their marriage properly done by the Italian law (the lady loved Italy) so they went to the Italian consulate in Japan, got one of those no impediment papers' translation authenticated/notarized, then went to Italy (along with their honeymoon), held the legal ceremony/registration there with witnesses, then reported the Italian law based wedding back in Japan after-the-fact.
Sometimes Japanese couples hold the ceremony (in a wedding hall or a shrine or a church) in Japan, which does not constitute a legal marriage yet, then rush to the city hall, submit the paper, then come back for the evening party :)
Anyway the difference is that in Japan what constitutes a marriage is THE paperwork at the city hall (the act of both parties turning in their paper is the marriage), and in the UK (and in many countries) the short ceremony done by the priest (in a church) or by a marriage superintendent (in a county hall in the UK, for example) and having it witnessed constitutes a marriage.
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