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In fact, as University of Notre Dame Law Professor Gerald Bradley has pointed out, "Consummation has traditionally (though, perhaps, not universally) been recognized by civil as well as religious authorities as an essential element of marriage. Pre-existing, incurable physical defects and incapacities which render a party unable to consummate the marriage, are, under most statutes, grounds for annulment. The law, in its rules regarding consummation, embodies an important insight into the nature of marriage as a bodily - no less than spiritual and emotional - union that is actualized in reproductive-type acts.