"Contract marriages" (or more strictly marriages "per verba de praesenti"), could be presumed, before the Marriage Act 1753, to have been undertaken by mutual consent couples who lived together without undergoing a marriage ceremony. However, they were not understood as having the legal status of a valid marriage until the decision in "Dalrymple" clarified this in 1811. This decision affected the subsequent development of English law due to the fact that the Marriage Act 1753 did not apply overseas. English courts later held that it was possible to marry by a simple exchange of consent in the colonies although most of the disputed ceremonies involved the ministrations of a priest or other clergyman.