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marry in japan and UK? 2011/8/15 11:55
hi
I am a British national living in Japan.
This spring I married my Japanese fiance, but we just completed the paperwork at the local city office.
We are hoping to hold our actual wedding in the UK soon.
Has anyone done this? The embassy in Osaka couldn't really give any advice except ask a lawyer, meaning if we have already married in japan, we might not be eligible to "marry" again in The UK.
If anyone would be willing to share their experiences that would be great!
thanks.
by alex (guest)  

... 2011/8/15 16:15
No lawyer here, but this is what I know. You can only get married once, according to one jurisdiction's law. In your case, if you got married based on Japanese law (by reporting your marriage to the city/ward hall), your marriage is one that is based on Japanese law, and that's it.

So you must have gone through all these procedures of getting the certificate of no impediment, and gotten married by Japanese law, I assume?
This page indicates the consulate's thoughts on people having married in Japan... scroll all the way down...
http://ukinjapan.fco.gov.uk/en/help-for-british-nationals/living-in-ja...

We did the reverse - we got married in a town in the UK (where we - an EU national and myself Japanese, lived back then), so our marriage is UK law-based. Later when we moved to Japan I reported our marriage to the Japanese authorities after-the-fact. But our marriage is still UK law based nevertheless.

You can have a wedding banquet back in the UK with family and friends, if that's what you want.

by AK rate this post as useful

the registration 2011/8/15 16:27
Actually you can 'register or marry" the same person again in UK. In UK, you will fill the column as -you have not married before - as it means you have not married to someone else before.

However, there is a difference in visas= wife/spouse/partner or fiancee/fiance procedure for UK Immigration. Visa depends on your next step after marriage in Japan.

When you registered marriage in Japan-it might be wise to bring certificate and register your marriage with British Embassy in Tokyo (and still hold your ceremony in UK without having to register again). This step means UK Immigration will allow your wife to enter and reside with you in UK.

If you fail to register your marriage with British Embassy in Tokyo, you have to apply for entry clearance for your 'fiancee' before your arrival and wait for approval before your 'fiancee' can enter UK.

Hope it helps
by Donaldl rate this post as useful

... 2011/8/15 16:46
register your marriage with British Embassy in Tokyo

If you scroll down the page I provided a link to, they say:

Once your marriage has been registered in Japan, there is no system to register your marriage in the UK. The British embassy and the British consulate-general in Japan do not register any marriages. Once your marriage has been registered in Japan, a British marriage certificate cannot be issued.

It seems to differ from country to country, but apparently British Embassy/consulate-general does not seem to have this procedure.

While Japanese authorities officially accepts UK-issued marriage certificates (reverse of what the original poster did), the UK authorities does not seem to have a procedure for this. I guess you will need to ask the marriage registrar office in the UK where you intend to get married.
by AK rate this post as useful

double marriage 2011/8/15 17:55
Dear AK and Donald,
Thanks for your info and link.
According to the British consulate there is "no system to register your marriage in The UK" . I've been puzzling over what that actually means? Is the marriage recognised in the UK or not?
I take Donaldl's point, about never having married anyone else before but is it legal to do that?ie check the never been married before column when actually I have, even if to the same person.
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 .
How do they get around the "double married" issue?
AK, thanks your sharing your experience. Your situation is the reverse of mine! So, when you came back to Japan, and you reported your marriage after-the-fact, I assume it was accepted by the Japanese authorities?
Anyone else any experiences to share? would love to hear them!
by alex (guest) rate this post as useful

Sorry it's gonna be long 2011/8/15 18:21
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.
by AK rate this post as useful

Re: marry in japan and UK? 2011/8/15 20:30
"no system to register your marriage in The UK"

When I married at the City Hall in Japan (well, just filed the form, really) the registration of my marriage in my home country (Holland) was optional. If you don't register, your marriage is still valid of course.
When I moved to the UK I had to apply for a visa for my wife here in the UK and we supplied English translations of our Japanese marriage certificate and had no problems, we recently obtained a permanent visa for my wife. Just make sure that you get the marriage certificate translated so it is an official document; we went to the Japanese embassy in Holland who translated the documents for a small fee.

Note the you can have as many wedding ceremonies in as many countries as you like, but you only officially marry once and judging by the messages above, you have already done that.
by Hoshisato rate this post as useful

complicated 2011/8/15 21:20
Thanks AK for your informative response! and Hoshisato too.
I see, I wasn't aware of that. It does explain why they (the british consulate) might recommend seeking the advice of a lawyer .
It might have been better to have done it your way, ie. marry in the UK and register it here in Japan .
Oh well, it will be interesting to see what else I can find out. I have contacted my local town hall in the UK and am awaiting a response. I'll update you if I find anything else out! Of course I could always seek the advice of a lawyer too!!

In the meantime thanks everyone for your input today!
very much appreciated.

by alex (guest) rate this post as useful

. 2011/8/16 11:22
I think the only reason the UK might not accept your marriage is you didn't get married according to Japanese law. Like if you got "married" at Disneyland and never registered the marriage at the city hall.

Members from some religions or cults or whatnot get married according to their own laws and they're not legally married in that country. The think the UK just doesn't recognize those type of marriages.
by . (guest) rate this post as useful

... 2011/8/16 12:02
To ". (guest)"

I believe the original poster DID get married according to the Japanese law (the paperwork is THE marriage procedure in Japan).

The British consulate-general in Japan does not seem to have a system for registering Japan law-based marriages, that's what we are talking about.


To alex,
I hope things work out fine for you! And I forgot to say... congratulations :)
by AK rate this post as useful

reregister 2011/8/16 12:23
According to the British consulate there is "no system to register your marriage in The UK" . I've been puzzling over what that actually means? Is the marriage recognised in the UK or not?

From my experience, this means that a proper marriage performed in Japan is automatically recognized and will not need to be registered. So they are saying that there is no system to register your overseas marriage because registration isn't necessary. At least that's how it works in the US and a few other countries where registration isn't possible.

if we have already married in japan, we might not be eligible to "marry" again in The UK.

No, you cannot have a legal marriage performed if you are already married, but what many people do is have the ceremony and just not sign the papers that would make it a legal marriage. I'm sure it varies by jurisdiction though.
by yllwsmrf rate this post as useful

. 2011/8/16 12:24
I believe the original poster DID get married according to the Japanese law (the paperwork is THE marriage procedure in Japan).

Yes, and that's why he shouldn't have any problems getting the marriage accepted in the UK.

The British consulate-general in Japan does not seem to have a system for registering Japan law-based marriages, that's what we are talking about.

To be clear, you can't register *any* foreign marriages in the UK--not just Japanese ones. If you're married you're married. No need to register it.
by . (guest) rate this post as useful

awaiting a response 2011/8/16 16:27
hello again,

Well, thanks for all your views! and the congratulations was nice to hear too :)

Just to clarify, yes we did do everything in accordance with the Japanese law regarding getting marriage, which as AK pointed out is just the paperwork. We didn't go to a shrine or have any wedding reception but we are officially married in Japan.
The main thing that's been confusing me is what

Once your marriage has been registered in Japan, there is no system to register your marriage in the UK. The British embassy and the British consulate-general in Japan do not register any marriages. Once your marriage has been registered in Japan, a British marriage certificate cannot be issued.


mean exactly , it is rather ambiguous. ... and why I need to ask a lawyer to find out if it is valid or not.


a consular officer may not give any form of guarantee that a marriage will be valid in English law. If you needed further guidance on this, you would have to consult a lawyer.


yllwsmrf, thanks for your comment, yes I see what you are saying and that's a possibility: but if it is automatically accepted then why the lawyer business?

I also asked in person at the British Consulate in Osaka but they couldn't give me a concrete answer.

I have contacted my local town office back in The UK but am still waiting to get a response.

Next thing is to contact a lawyer.

Thanks again everyone!


by alex (guest) rate this post as useful

lawyer 2011/8/16 17:16
Once your marriage has been registered in Japan, there is no system to register your marriage in the UK. The British embassy and the British consulate-general in Japan do not register any marriages. Once your marriage has been registered in Japan, a British marriage certificate cannot be issued.

mean exactly , it is rather ambiguous. ... and why I need to ask a lawyer to find out if it is valid or not.


It sounds pretty clear to me, if you consider that the marriage certificate is a legal document. Getting a marriage certificate from the UK when you already hold one in Japan isn't possible because you would be trying to get married while already married. Its not like you are making a copy of your Japanese marriage into the UK registrar, its more like getting married again without divorcing your old spouse (despite the fact that they are the same person).

But yea, better consult a lawyer to be on the safe side. Unfortunately that will cost some money.

a consular officer may not give any form of guarantee that a marriage will be valid in English law. If you needed further guidance on this, you would have to consult a lawyer.

yllwsmrf, thanks for your comment, yes I see what you are saying and that's a possibility: but if it is automatically accepted then why the lawyer business?


Consulate officer aren't lawyers, nor (surprisingly) are they experts in these international matters, so I'd be wary of their advice anyway. In my experience they only know things from their side of the table. But overall, I think its just an example of CYA. That way they can be general and still cover all possible situations.
by yllwsmrf rate this post as useful

update 2011/8/29 17:02
hello everyone,

just wanted to post an update on the issue regarding getting married in the UK and Japan. I have been in contact with the local registrar office and this is a summary.

First of all, if the marriage is legal in Japan then it is recognised in The UK.

As to whether we can get married again in the UK the official and somewhat surprising answer is :

yes, we can get married in The UK , even though we have been officially married in Japan and we would both be marrying the same person.

The only issue to be concerned about is the visa.
If we are already married then my partner would need a spouse visa but after the marriage it might look like he's on the wrong visa which could pose problems with the entry clearance offices.

So i f we are careful about that, then we can go ahead and get married again! I think this is what Donaldl mentioned earlier.

So, thanks again everyone!





by alex (guest) rate this post as useful

Re: marry in japan and UK? 2014/5/7 20:15
Really interesting post. I know it was posted a few years back but I am interested with you last post you made ALEX what the outcome was.

I married my wife in JAPAN and like you was unsure whether you could re register again and I read on the Embassy website that once your married cert is sent to the embassy it is translated and sent to the Gro for their purposes. But this doesn't mean you re-register by doing this.

Regards.

Jon
by hfgryuskfv rate this post as useful

Re: marry in japan and UK? 2014/5/8 14:48
I married in Japan and we lived in different European countries among which was the UK. You don't need to register your marriage back home, I got my Japanese marriage certificate from the City Hall in Japan and had it translated by the Japanese embassy once and I'm still using that document as proof of marriage whenever and where ever I need it.
For the authorities back home, you're married :-)

by Hoshisato rate this post as useful

Re: marry in japan and UK? 2014/5/9 02:04
I see. So I am interested do you plan to live in JAPAN too? Really really love JAPAN and we are looking at living out there together one day but I have no Idea what I would so because of the language difference and I would be mostly competing with people with degrees
by hfgryuskfv rate this post as useful

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