Sec 398

It has also been held that all agreements to bring about marriages for a money consideration are void. The reason given is, that parties in a matter so important and so essential to the state as marriage should not be exposed to the machinations of speculators.1 Even a bond given by a party after marriage in consideration of assistance rendered by the obligee in effecting the obligor's marriage, has been held void.2

Sec 399

Not only is a fraudulent settlement by a woman, on eve of marriage, of property of which he is cognizant, and which he might therefore be supposed to marry on the faith of, void as against the husband,3 but he is also held entitled to avoid settlements made by her in fraud of his marital rights of property of which he has no knowledge.4 Nor will an ante-nuptial contract by the woman, without a fair disclosure of her husband's circumstances, be enforced against her.5 A fraudulent conveyance,also, by a man in prospect of marriage, in such a way as to deprive the wife, if successful, of dower, will be void against her.6

Marriage brokerage contracts void.

Marriage settlements in fraud of marital rights will be set aside.

1 1 Story Eq. Jur. sec 263; 1 Fonbl. Eq. B. 1; Keat v. Allen, 2 Vern. 588; Hylton p. Hylton, 2 Ves. 548; Law v. Law, 3 P. Wins. 394; Boynton v. Hubbard, 7 Mass. 118.

2 Williamson v. Gihon, 2 Sch. & L. 357.

3 Supra, sec 266; Bispbam's Eq. sec 253; England v. Downs, 2 Beav. 522; God-dard p. Snow, 1 Russ. Ch. 485; Williams v. Carle, 2 Stockt. Ch. 543; Waller v. Armistead, 2 Leigh, 11; Manes v. Durant, 2 Rich. Eq. 404; McAfee v. Ferguson, 9 B. Mon. 475.

4 Goddard v. Snow, 1 Russ. Ch. 485; Chambers v. Crabbe, 34 Beav. 457; Taylor v. Pugh, 1 Hare, 608; Linker v. Smith, 4 Wash. C. C. 224; Tucker v. Andrews, 13 Me. 124; Terry v. Hopkins, 1 Hill Ch. 1; Williams v. Carle, 2 Stockt. 543; Duncan's App., 43 Penn. St. 67; Robinson v. Buck, 71 Penn. St. 386; S. C, 8 Phil. 87; Belt v. Ferguson, 3 Grant, 289; Greenawalt ex parte, 2 Clark, 1; Logan v. Simmons, 3 Ired. Eq. 487; Baker v. Jordan, 73 X. C. 145; Jordan v. Black, Meigs, Tenn. 142; Freeman v. Hartman, 45 111. 57.

5 Kline v. Kline, 57 Penn. St. 120; Kline's Est., 64 Penn. St. 122; cited supra, sec 161.

6 2 Bishop, Married Worn. sec 343; Wald's Pollock, 289, where the oases are cited; Schouler on Dom. Rel. 271; Bisp. Eq. sec 499; Gibson v. Hutchinson, 120 Mass. 27; Swaine v. Perrine, 5 Johns. Ch. 482; Pierce v. Pierce, 71 N. Y. 154; Petty v. Petty, 4 B. Mon. 215; Leach v. Duvall, 8 Bush, 201; Gainor v. Gainor, 26 Iowa, 337; Crawson v.Crawson, 4Mich. 230; Brown v. Bronson, 35 Mich. 415; Littleton v. Littleton, 1 Dev. & B. 327; Tate v. Tate, 1 Dev. & B. Eq. 22; Davis v. Davis, 5 Mo. 183; Butler v. Butler, 21 Kan. 521; Hamilton v. Smith, S. C. Iowa, 1881. See Killinger v. Reiden-hauer, 6 S. & R. 532.

The question of fraud is to be determined from all the circumstances of the case;1 secrecy not necessarily implying fraud.2 - The wife, after her husband's death, may elect, if the conveyance be fraudulent, to set it aside; and a court of equity can be invoked for this purpose.3 Whether such conveyance was made with intention to defraud the intended wife is to be determined from all the circumstances of the case.4 The burden is on the party setting up the fraud.5 A strong inference of fraud is to be drawn from the fact that there is a secret reservation for the husband's benefit.6