A marriage by verba praesenti valid in Scotland was also valid in England. There was a celebrated case in the first decade of the 19th century involving a member of the Manners family, one of the younger sons of the Duke of Rutland. While his regiment was stationed in Scotland, he entered a liason with a Scots girl. When the regiment marched away, so did he, leaving her behind in the immemorial manner of young officers on foreign station. Some years later, when he was about to be married to a wealthy young woman suitable for his position, his former love turned up in England, claiming to be Mrs. Manners and bearing letters which, she said, proved it.

Manners sued in the Church courts for "jacitation of marriage," i.e. a declaratory judgment that he had never been validly married to the young woman. He lost; the ecclesiastical judge ruled that the exchange of letters constituted a binding marriage by verba praesenti under Scottish law, and he was well and truly married. What happened next I do not know.