New York long as enjoyed the dubious distinction of being the most flexible jurisdiction for the granting of annulments of marriages. As a student of the subject relates, "For those unable or unwilling to travel and assume residence outside the state, New York offers an unusually expansive concept of annulment to mitigate the severity of the divorce law." There is some anticipation that the recently revised divorce statute will tend to make annulments less appealing and attractive to those who are incapable of resorting to foreign forums for the severance of the marital tie. Annulments for fraud are allowed to be instituted by sections 7 and 140 (e) of the New York Domestic Relations Law. Do the subjective elements of love and affection play any meaningful role in ascertaining the grounds for fraudulent conduct in the arena of annulments?
Samuel Abrahams, Annulments for Lack of Love and Affection, 16 Clev.-Marshall L. Rev. 180 (1967)