## Facts

- David Singh and Seoranie Singh married in Connecticut in 1983 believing they were not related.
- After learning they were related (understood as an uncle–niece relationship), they jointly sought annulment.
- In 1984, a Connecticut trial court entered a judgment of annulment declaring the marriage null and void.
- Later investigation showed Seoranie was the daughter of David’s half-sister, making the parties half-uncle and half-niece.
- In 1988, the parties remarried in California, where the marriage was not prohibited.
- The parties jointly petitioned in Connecticut to reopen the 1984 annulment, arguing Connecticut’s incest statutes did not expressly include half-blood relations.
- The trial court denied reopening, concluding the statutory bar turns on the prohibited degree of relationship, not whether the relationship is whole-blood or half-blood.
- The parties appealed to the Connecticut Supreme Court.

## Issues

1. Whether Connecticut’s incest marriage prohibitions apply to relationships by the half blood as well as the whole blood, making a half-uncle/half-niece marriage void.
2. Whether the 1984 annulment judgment should be reopened based on the later discovery that the parties were related by the half blood.

## Decision

- The Connecticut Supreme Court affirmed the denial of the motion to reopen the annulment.
- The court held that Connecticut’s civil and criminal incest statutes prohibit marriages within the stated degrees of consanguinity without distinguishing between whole-blood and half-blood relatives.
- The court concluded a marriage between a half-uncle and half-niece is incestuous and void under Connecticut law.
- The court treated the parties’ later California marriage as irrelevant to Connecticut’s refusal to recognize incestuous unions as consistent with state public policy.

## Legal Principles

- Statutory prohibitions on incestuous marriage stated in terms of degrees of relationship (e.g., “uncle” and “niece”) apply to half-blood relatives absent express statutory language limiting the prohibition to whole-blood relations.
- Civil marriage prohibitions and related criminal incest provisions are construed together when they implement the same policy against incestuous unions.
- Connecticut will not recognize a marriage valid where celebrated if it falls within a category Connecticut treats as void on strong public-policy grounds.
- A judgment of annulment need not be reopened where the original marriage was void under the governing statutes; later-discovered details about the parties’ lineage do not alter the statutory application when the prohibited degree of relationship remains the same.

## Conclusion

The court held that Connecticut’s incest statutes bar marriage between a half-uncle and half-niece, so the parties’ marriage was void and the prior annulment remained legally correct and not subject to reopening.


Singh v. Singh, 213 Conn. 637, 569 A.2d 1112 (Conn. 1990)