When women win:
Male-female disputing in Kaliai,
West New Britain

Dorothy Ayers Counts
University of Waterloo

David R. Counts
McMaster University

1994. Counts, Dorothy Ayers and David R. Counts. When women win: Male-female disputing in Kaliai, West New Britain. In Law and Anthropology. International Yearbook for Legal Anthropology, Volume 7., pp. 331-352. René Kuppe and Richard Potz eds. Dordrecht: Martinus Nijhoff. This version differs slightly from the published version. Please cite the published version.

Studies of Melanesian dispute settlements usually emphasize disagreements between men or else focus on male dominance over females in social conflict. Nevertheless, Melanesian women do win disputes with men, as Strathern's micturating woman reminds us.(1) In this paper we examine case studies of disputes from the Kaliai area of West New Britain Province, Papua New Guinea in which women have won. Our analysis of disputes seeks to discover what strategies were effective, whether women successfully use different strategies than do men, and whether a dispute between women differs from a dispute between a woman and a man.

Our data for this paper, presented in the Appendix, consist of eleven case studies of disputes that occurred at the village level. Some were resolved informally between the disputants and other interested parties, others were settled in village moots, while in still others resolution was reached by a magistrate at a local court hearing. The basis of some settlements was precedent set by decisions by government magistrates in other cases. Other settlements were reached as a result of local belief regarding the probable outcome of a court case. We have detailed information for nine of these case studies. Six disputes were between wife and husband; three were between a woman and her kin; two were between women. Two of the cases are complex ones that encompass at least two sets of disputes. In one a young woman used different strategies to resist attempts to force her to marry two different men. In the other a wife pressed adultery claims against both her husband and the other woman.


The people whom we discuss in this essay speak Lusi, an Austronesian language and live in villages and hamlets along the northwest coast of the Kaliai electoral district of West New Britain Province. There are approximately one thousand Lusi speakers in total; our data were collected among the approximately 350 people of Kandoka village and its associated hamlets over a period of nineteen years of field research between 1966 and 1985.

Northwest New Britain is physically isolated from any developed area. The Kaliai can, nowadays, get to the bustling town of Kimbe after a sea journey of about seven hours by motorized canoe, and once there they can buy manufactured items (clothing, beer, liquor, tools, packaged foods) with the money that they receive from selling their copra (the dried meat of coconuts), the area's primary cash crop.

The Lusi-Kaliai practice slash and burn subsistence horticulture and supplement their diet with sea food, wild pigs, and other game. A few have jobs away from their home village. Most of what the villagers have, they produce themselves.

The people of Kaliai have been the object of sustained missionary activity by the Roman Catholic church since 1949. By 1985 all of the adults of Kandoka had been baptised into the Catholic church. Kandoka also supports a local primary school that provides education to standard six. Approximately one-third of the children go on to high school, and one young woman has received a bachelor's degree from the University of Papua New Guinea and in 1992 is completing graduate training in fisheries resource management at a Canadian university.

The villages of coastal Kaliai are similar in appearance. Houses in a village typically stretch along the beach in two lines facing each other across a public plaza-like space, backed up to the sea on the north. Houses are built of local materials, usually raised off the ground a few feet, and thatched with fronds of the sago palm made into large shingles. Scattered among these dwelling houses are men's houses, where young bachelors and elderly widowers sleep and where ceremonial materials (ancestor masks and the like) and other 'men's gear' (e.g. large handmade rope nets for pig hunting) are stored. A typical Lusi-Kaliai village combines two or more hamlets, often is near a primary school, and contains a locally owned trade store and perhaps a small chapel or aid post. Although it is difficult for an outsider to see, most of the people of the main village of Kandoka where we have done research actually live in one of four separate hamlets. Each hamlet consists of a cluster of houses together with the men's house appropriate to the group that lives there. The focus of each hamlet and its men's house is a group of people related (mostly) patrilineally. The group, called a kambu, forms a patrilineage. When a woman who is a member of such a group marries, she usually moves into the hamlet or village of her husband's kambu. Thus the people who live, garden, and make copra together are usually a group of married men who are relatives, their wives, and unmarried children of both sexes.

When a couple marries, the groom and his kin pay bridewealth to the kin of the bride. As each child is born to a marriage the father's kin make payments to the mother's relatives. When the first-born child is between six and ten years old, the father's family sponsors a ceremony during which large gifts of shell money, pigs, and other valuables are presented to the mother's relatives. These payments affiliate the first-born child (and by extension all children of the marriage) with the father's kambu and men's house. The payments also signify that married women remain members of their own kambu and that the children these women bear for their husband's groups are also kin to their mother's kambu.

Most things of importance, such as disposal rights in gardening land, kambu membership, and the right to use emblems and artistic designs or wear certain ancestor masks descend from fathers to their children. The importance of the links between children and their mother's kin is recognised in the inheritance of coconut palms, which descend matrilineally.

Before the 1950s, in the days when Kaliai contact with colonial government officials was brief and infrequent, each person needed only a few coconut palms. Coconuts provided refreshing drinks to welcome guests, were snack foods, and were a essential component in the taro puddings that are a necessary part of any feast. They were also used as a source of oil for cooking and as food for domestic pigs. After World War II, when the colonial government began to insist that the people of each village plant coconuts and process the meat into copra for sale as a cash crop, the importance of coconuts changed. Where coconut was once primarily a food, it is today almost the only source of cash income for the villagers aside from remittances. This is a situation made for conflict, as one of the cases suggests. Parents want their own children to inherit the source of money in which they have invested their time and effort, and a coconut plantation will bear fruit and be a source of such income for nearly a century. Meanwhile, young people look at the plantations that their mother's brothers have established knowing that they should be the heirs of those palms, just as their parents inherited from their mother's brothers.

The people of Kaliai may be said to live in an egalitarian society for there is no ranked hierarchy and no formally inherited office; but people are not equal. There is, for instance, no gender equality in this society. Power differences exist on the basis of age, sex, and birth order, and traditional norms stress the authority and dominance of men. A first-born male has an advantage over women and younger men, and a man ordinarily has authority over his wife, daughters and other female relatives, especially younger ones. Although he has this advantage, his ability to use it is restricted by a number of conditions including idiosyncratic differences in personality and character which, combined with birth order and relative age, may permit a strong-willed woman to dominate her younger male relatives.

Political leaders are called maroni and follow the classic bigman model as described by Sahlins (1963).(2) Bigman status is restricted to males and is achieved through acts of conspicuous generosity that indebts the recipients. Aspiring bigmen assist younger men in accumulating the wealth required for marriage and to sponsor the ceremonies that affiliate children to the father's lineage and men's house. They also sponsor mortuary ceremonies that bring closure to the relationships of sharing and exchange built up over the lifetimes of other bigmen. The valued wealth items required for these presentations include locally produced items such as fathom lengths of fine shell bead currency called vula,(3) pandanus mats, and pigs. Clay pots, carved wooden bowls, and shell bracelets obtained in trade are also an important part of any ceremonial distribution. These same wealth items -- especially vula, mats, pigs, and (nowadays) currency -- also make up the compensation payments that are usually required as part of the dispute settlement process.

Most public disputes take place between men and involve quarrels over rights in women; claims of debt; destruction of property -- including gardens -- by men or those for whom they are responsible including their pigs; accusations of sorcery; disagreement over the ownership of land, cash crops or other resources and/or theft of same; and personal injury. Men usually settle their quarrels by the payment of compensation which is either arrived at by negotiation between the adversaries or as the result of mediation by a disinterested party. A man may also end a dispute by shaming his opponent. A man shames another by publicly refusing to accept a gift or a payment that is legitimately his due or by publicly giving an adversary something so valuable or in such enormous quantities that it is obvious that the opponent will be unable to reciprocate. Disputes that are not settled satisfactorily can be expected to surface at a later time in conjunction with a different quarrel and complicate the resolution of the new conflict. Unresolved disputes may eventually lead to physical violence, sorcery, and/or death(4)

Traditional Social Institutions and Legal Principles

Before we examine the kinds of disputes in which women become involved as principal participants and the strategies that they use to win, we must first note the cultural context in which litigious women operate.

(1) Both custom and provincial law recognize different marital rights for men and women. Polygyny is practiced, although polygynous marriages are the exception rather than the rule -- 4 of 75 male Kandokans householders were married to 2 wives in 1985. But no woman may have multiple husbands. While a husband holds exclusive rights over his wife's sexuality, a woman has only limited rights over the sexuality of her husband. For example, even though a man may take a second wife, he may not have casual affairs. A woman is justified in threatening or doing violence to her husband, or in taking him to court, if he has an affair with another woman. If, however, he subsequently marries his lover, the first wife has no recourse. If she attacks her husband or co-wife, or if she commits adultery, she is culpable. If she leaves her husband she loses custody of her children.

There are a number of social factors that contribute to this situation. As Modjeska observes, the degree to which men have authority over women may vary according to the kind of marriage rules found in a particular society.(5)

In societies where local endogamy and child betrothal occur, these practices assure male control and undermine female independence. The custom of bridewealth and childwealth payments separates women from rights in their children as well. Until the 1960s most Kandokan marriages were contracted by arrangements made between the father or brothers of a woman and the family of her future husband. Although the negotiations might be opened at the request of either of the young people, older people assert that neither potential marriage partner had control over the person to whom he or she would be married, or over the conditions under which the marriage would take place. Despite these assertions, a number of life histories that we collected provide early counter examples in which young people successfully defied their elders and eloped with partners of their choice. The external influences of church and school, and the exposure of young people to Western courting practices and the ideals of romantic love, have changed the traditional pattern even more profoundly. Today young people defiantly assert their right to choose their spouses, and most do. Even in those cases where a marriage is arranged between the young couple's parents, the arrangement is tacit recognition of the couple's desires and often of the already established fact that the young people are living together and, perhaps, expecting a child.

Modjeska also points out that in those societies where bridewealth legitimates men's control over women or promotes the attitude that they are the property of their husbands, male dominance in family relationships is more pronounced. This dominance is likely to lead to wife bashing which may be condoned by both women and men and is seen as an aspect of marital sexual relations. (6)

Because of the difference in marital rights of women and men, women do not often take their adulterous husbands to court. We know of only two occasions when Kaliai women charged their husbands with adultery in district court. In both cases the women took this step after successfully claiming compensation from their husbands in village moot in an attempt to break up the affair. In court both men paid fines, and in one case the husband ended the relationship with the other woman. In the second case he married her, thereby ending his first wife's access to further redress.

(2) The matter of who holds rights over an unmarried woman's sexuality is disputed. Traditionally those rights were held by her parents, especially her father, who had the duty and right to arrange her marriage. These rights were transferred, upon the payment of bridewealth, from her father to her husband. Modern young women claim those rights for themselves and either elope with the men of their choice or resist attempts to force them into arranged marriages with men whom they have not chosen.

(3) Violence is accepted as a part of married life in Kaliai.(7)

Most women expect that during their married lives their husbands will beat them, and many might agree that their husbands had a right to do so -- within limits. Domestic violence occurred in all six of the disputes between husband and wife analyzed here; the wife was beaten by her husband in four cases, and the wife either fought back or initiated an attack against her husband in three. In two cases the woman made the violence against her an issue. All three of the men responded to their wives' violence by escalating the conflict. One attempted suicide. One fled for sanctuary into the center of a mortuary ceremony, disrupting it and thereby involving the community in the controversy. The third took the domestic quarrel into the public domain by calling in ancestor figures to shame his wife and enjoin her from further violence against him.

(4) Female suicide occurs frequently in Kaliai, so much so that it is a source of public concern. In a population of about one thousand people, there were eight suicides and two suicide attempts by Kaliai women between 1966 and 1985, seven of the successful ones between 1975 and 1985.(8)

Villagers are sensitive to the possibility that a shamed or abused woman may kill herself and the threat (or even the reminder of the prospect) quickly generates public support for a female litigant.

Before we analyze the cases presented in the Appendix, we must clarify what we mean by 'winning'. In only two of the eleven cases did the woman take her grievance into the court system where a formal decision establishing the winner and loser was handed down. The other nine conflicts were settled (1) when a woman employed a self-help strategy which caused her opponent to yield (for example attempting suicide, physically attacking and shaming her opponent, destroying property); (2) as a consequence of spontaneous public interference resulting in an informal gathering where public opinion coalesced and was expressed; (3) or by a public moot (lupunga) called specifically to deal with the controversy. How, then, do WE know that a woman won, and what do we mean by win?

First, we consider that a woman won a dispute if she achieved her stated goals. Women lose if they are thwarted in their attempt to achieve a stated goal. In the cases presented here, the goals were as follows: the woman was not required to marry against her wishes (three cases, two examples in one complex case); she established her right to inherit use and disposal rights in a cash crop (one case); her husband was fined for beating her (one case); she prevented her husband from taking a second wife (two cases); her husband was fined for committing adultery (two cases); the other woman was fined for committing adultery (one case in conjunction with a fine against the husband); her husband ceased beating her when she fought with her co-wife (one case); her husband did not divorce her (one case); she divorced her husband (one case); she received equitable treatment from her husband (one case).

Second, in four of the cases (two court decisions and two decisions in moot) public statements established culpability and set fines or compensation to be paid. In the other seven no public consensus was expressed and no decisions were announced. As villagers advised us, in a moot one must wait and see what happens in order to know who wins. We consider that the woman won if her adversary acceded to her demands (her husband dropped plans to take a second wife; her kinsmen stopped collecting coconuts from palms she claimed; her husband no longer beat her when she fought with her co-wife; her husband ceased demanding a divorce and she returned to his house). We should note that in most of these cases a woman won when she STOPPED someone else from engaging in behavior offensive to her, or when someone who had violated her rights was required to pay a fine or compensation. In only four cases -- three involving a young woman's right to choose her husband or to divorce him for abuse and one in which the woman was empowered to continue to harvest the coconuts from a plantation as her right -- did the woman gain public recognition of her right to behave as she chose.

Strategies Used by Women

In order for a woman to win a dispute she should obtain the backing of her kin or community by establishing that she is in the right. If they believe her to be in the wrong they may refuse to help her, thereby preventing her from winning. For example, Alice's husband was convinced that she had taken a lover while they lived in Rabaul and, although she had returned to the village with her husband to live, he continued to suspect her of infidelity. After he beat her severely, she left him and went to stay with her adult daughter. Late one night her husband entered the house where she was sleeping and attempted to kill her with a hatchet, but she escaped. A few days later Alice asked her maternal kin to allow her to go with them to Kimbe in order to flee her husband. Because they thought her husband's assessment of her infidelity was correct, they refused to allow her to accompany them.

If there is doubt about the merits of a woman's case, she must convince both her potential supporters and opponents that she will press her claim and will escalate the dispute until the cost of defeating her is more than her opponent is willing to pay. For example, in case eleven a woman's willingness to use violence convinced her kin to support her demand to end her arranged marriage. If she is persuasive and demonstrates her willingness to escalate the dispute she may win even though she lacks support. See, for example, case eight in which the woman won a partial victory even though she lacked community backing.

A woman convinces others of the seriousness of her grievance and of her willingness to escalate the conflict in a number of ways. If she has the knowledge and the strength of will, she may take, or threaten to take, the dispute outside the traditional system to church officials or to the courts.

The court system provides support for women who take their cases there, and a woman may choose this alternative if her opponent has the stronger case by customary standards and/or she (and the community) believes that the law supports her claims and will levy a heavier penalty on her opponent than would the moot if the dispute were settled by traditional means.(9) Women successfully took a dispute to court in four cases. In case one Karen threatened to go to court even after village officials announced that her opponents would be required to pay a substantial compensation by village standards and warned that the total expenses of a court settlement would work a severe hardship on her opponents. Similarly, in case five a wife charged her husband with assault and caused him to pay a fifty kina fine for a beating that was not unusually harsh by traditional standards and that probably would not have resulted in the husband's paying compensation had the dispute been aired in a village moot.

The church is less useful as an arbiter on behalf of women, partially because people do not consider the sanctions imposed by it to be efficacious, and partially because the rules of church and state are sometimes in conflict. Although the rules of the Roman Catholic church prohibit polygyny, provincial law does not, and people may choose to ignore church sanctions. For example, when the local priest barred Dotty and Sol (see case ten) from taking the sacraments because he considered their relationship to be adulterous, they simply stopped attending church services. No one in the village criticised them with the exception of Sol's mother.

A woman may also convince others of her willingness to escalate the dispute by violent behaviour. For example, when Louis announced that he intended to take Sally as his second wife, Melinda used violence in an attempt to prevent the marriage. She beat Sally on several occasions, and on two occasions threatened to kill her with a knife or by drowning. When this strategy was unsuccessful, Melinda persuaded Louis to reinforce their traditional marriage (which had been legitimized by a ceremony in which bridewealth had been presented and gifts exchanged) by a church ceremony. Then Louis brought Sally (the new wife) to the village to stay with his family while he went to Papua to work, and they accepted her as Louis's second wife. Enraged, Melinda returned to her father's house to live and the two groups began to dispute over custody of the couple's three children. After the affair that caused a public controversy (see case one), Louis announced that he and Melinda were divorced and his family took custody of the children. Melinda did not challenge their claim in court because, she said, she knew that provincial law would support Louis's claim and award the children to him.

Although her willingness to resort to violence does not always allow a woman to win a dispute, as we see in the example of Melinda and Sally, willingness to initiate violence in order to achieve their ends was an important component in the strategies of the women who were successful. A woman may legitimately threaten violence against an individual -- her husband or the other woman -- who has violated her marital rights. In cases one and six the women were behaving acceptably when they threatened their husbands with weapons. Neither Karen nor Patsy were publicly criticized, neither woman was required to pay compensation, and their husbands -- surprised and shamed -- did not even try to fight back. If a woman has community support when she threatens extreme violence against her husband for an adulterous affair, she is likely to win.

Violence may also be expressed by the destruction of property: her property, property she shares, or property under dispute. Note two things here. First, the ultimate statement of ownership in Kaliai is the destruction of the thing claimed. Full ownership rights include the right to use, the right to temporarily extend use rights to others, the right to control, and the right to alienate. The right of ownership is the right to destroy. By extension, when Karen and Patsy chased their husbands with weapons, threatening to kill them, the women were publicly asserting their rights over their husbands and, although actual murder would not have been acceptable, the metaphorical statement of the rights of a wife over her husband was generally understood and appreciated. Second, destruction of one's property is a clearly understood metaphor for suicide, the destruction of one's self. In the context of Kaliai culture, therefore, destruction of property is an unequivocal statement that someone is seriously aggrieved. Such a statement quickly commands community attention.

Even without community support a woman may win a partial victory over an abusive husband by threatening violence against herself. Note that in case eight Mary's violence against others was not approved by the community. Even her own children took her co-wife's part in their fight, and her husband called on ancestor figures to publicly enjoin her violence against him. Nevertheless Mary's violence against herself convinced her husband not to beat her or to interfere in her fights with her co-wife. Thus she partially accomplished her ends.

Contrasting Strategies and Gender Roles

The primary winning strategies used by women and by men reflect different Kaliai assumptions about gender roles. Control and authority is not vested in women who are supposed to defer to their men folk. Men claim dominance both in the home and in the community, and may use force to underscore it.(10) Within limits a man has the right to treat his wife and female kin with violence. He has the right to punish, but not the right to destroy. A woman does not have the legitimate right to meet her husband's physical punishment with like violence: she is not supposed to fight back. She does, however, have the right to destroy those things that are hers. And this right apparently includes the right to threaten to destroy the individual in whom she has marital rights if those rights are violated. We say 'threaten' because we know of no case in which a woman legitimately assaulted and inflicted severe physical punishment on her husband.

As we have already noted, women are most often successful if they take disputes outside the community and into the government legal system, or if they threaten or commit violence. The strategies usually employed by men are different. Lusi-Kaliai men seldom take disputes against other men to court, they never do so when they are disputing with women, and they attempt to persuade women to use traditional methods rather than to go to court. Only the ex-sergeant, who spent twenty-five years in police service and who had confidence in the fairness of government law and court procedures, was consistently ready to take disputes into that arena. He was certain that the courts provided an equitable method for settling quarrels justly and in a way that would prevent escalation, but his attitude is rare. With the exception of the sergeant, men who escalate their conflict outside the traditional system are admitting the weakness of their claim by customary standards. Furthermore, court officials are usually strangers, strangers who will make a judgment according to a set of Western-based laws that Kaliai may not understand and/or with which they may not agree. Therefore, most Kaliai men prefer to settle their differences within the community using traditional procedures of self-help, negotiation, or the moot.

Given that Lusi-Kaliai women may be presumed to have less cultural knowledge of the outside world than do the men of the community (who have worked and been educated outside in greater numbers and for a longer time), it is paradoxical that men are reluctant to seek outside redress while women give every evidence of willingness to do so. This may be because women have fewer avenues of successful traditional redress than do men, and that the ones they do have are useful only in extremis. A little, poorly understood, knowledge of external support may make the courts a more attractive solution to a woman than to a man.

The destruction of property as an expression of extreme grievance is practiced by both men and women, but men are less likely to destroy their property than are women, just as they are less likely to destroy themselves. There are a number of reasons why suicide or the threat of suicide is an effective strategy for women. For our purposes here we note that attempted suicide is not shameful for women because they are assumed to be relatively powerless, and suicide is at least in part the expression of that condition. Self-destructive acts by men are admissions of shame, of defeat, of powerlessness and of loss of control. Men win by a show of strength and, therefore, self-destruction is not an effective strategy for them. Dorothy Counts has argued elsewhere that suicide is an effective political strategy for powerless persons in Lusi-Kaliai society. Therefore, suicide is an option more likely to be chosen by women than by men.(11)

Suicide is the ultimate cry for justice made by a person who perceives herself to be bereft of other means of redress. It enables a woman, in extrmis, to take control of her life and of her fate. In this paper we extend that argument, asserting that women are able to use the threat of self-destruction, either actual or metaphorical, as a much more effective legal strategy than are men. Further, women are willing to seek outside relief more frequently than are men for the same reasons that they are more willing than men to become destructive: having little to lose and few options to choose among in a conflict with a male, any path that offers hope becomes an effective one.

Appendix: Case Studies

The following are the data on the case studies on which our analysis is based.

Case 1

A public meeting or moot was called to settle a marital dispute and the disruption of public events. Disputants are Karen vs Stanley and Karen vs Melinda.(12) This dispute occurred in 1985.


Karen, a young woman from a neighbouring village married to a young man from Kandoka (Stanley);

Stanley, Karen's husband, adulterous lover of Melinda, and classificatory son of Louis, Melinda's absent husband;

Melinda, first wife in a plural marriage to Louis, current lover of Stanley, mother of three small children;

Louis, an absent school teacher, husband to Melinda, classificatory father to Stanley, also husband to Sally who is living in Kandoka.

Sergeant, a retired police sergeant, father to Louis, and classificatory grandfather to Stanley.

Summary of the facts: During a mortuary ceremony where masked ancestor figures (aulu) were dancing, Karen went into her house and found Stanley and his lover, Melinda there together. Brandishing her bush knife, Karen chased Stanley out of their house. Stanley ran into the circle of aulu figures, causing confusion and alarm. The ceremony's sponsor stopped the proceedings and performed a ritual which 'tabued the aulu'. As a result of the ritual, until compensation was paid to the masked figures, thereby lifting the tabu, no outsider could sleep in the men's house and the aulu could not dance again. The consequences of this tabu were serious ones. The reputations of the sponsors were at stake, for the ritual was an important one honouring their father. If they were unable to complete it they would be objects of scorn and contempt. Furthermore, the ceremony had drawn many visitors from other villages who were sleeping in the men's house. If the dispute prevented the village from offering hospitality to these visitors, the village would be shamed.

Following the placing of the tabu, the ceremony's sponsor demanded compensation from Karen and Stanley. In response, Karen left Kandoka for her natal home in the village of Atiatu about ten kilometres down the coast, and Stanley disappeared. The next day he flagged a passing boat and left for points unknown.

Foiled by his escape from collecting from Stanley, the sponsor's relatives went to Atiatu to return Karen to her husband's village and to collect compensation from her. On their return, they reported that Karen's father had told them, "It's alright for you to fine her, but you should also listen to what she has to say because she has been wronged." After giving her account of events, Karen had returned to Kandoka with her escort. When Karen and the sponsor's delegation returned, they informed the sponsor, the local government councillor, and the village committeeman what had happened. After considerable discussion they agreed that a moot must be called to settle the dispute.

During the moot, Melinda, the accused adulteress, was one of the first to speak:

"Yes, I've been sleeping with Stanley, but I didn't start it. He did. I didn't want to at first, but there was gossip about me. Some women slandered me and every time I went to the store to buy something for my children they wondered where I got the money. I was worried about my children. Louis deserted us and doesn't send anything for the children. Stanley said he'd marry me and take care of the children, so I weakened."

When she was asked about the state of her marriage, Melinda said: "It was never a good marriage. Louis didn't care about us. I never much wanted to marry him anyway, but he seduced me."

Following her speech the village officials summarized the facts as they saw them. Melinda had admitted adultery and Karen was a witness to the affair. Therefore, Stanley owed compensation to Louis because he had committed adultery with Louis's wife and Melinda owed compensation to Karen because she had engaged in sexual relations with Karen's husband.

Sergeant, senior relative of the two men, then spoke:

"The two women are here and their differences can be settled. But Stanley's father (Louis) isn't here, and Stanley isn't here, and we can't settle things without them. If we decide something I can hear what you have to say and give my opinion. But if I agree to anything and Louis comes back and doesn't like it, then he'll be angry with me. I've raised my children and set them free. They're married adults and must speak for themselves. I can't divorce Louis' wife, I can't take her to court, I can't take Stanley to court, and I can't accept a customary payment on Louis's behalf and say that it's finished."

Sergeant then asked who had jurisdiction should the matter be taken to court. The local government councillor replied that the local magistrate had jurisdiction. If the dispute was not settled amicably it could be appealed to the district magistrate at Cape Gloucester. If it went to court Melinda and Stanley would each have to pay at least 200 and perhaps as much as 300 kina.(13) In addition they would have to pay transportation costs for all the litigants and witnesses, court costs, and compensation to the aulu as well. Consequently, the costs of a court appearance would be much more than K300 each.

Sergeant: "Not only can it not be settled because Louis isn't here, it can't be settled because it is a legal (church) marriage."

Councillor: "Look, let's find out. Karen, do you want to settle this by custom, or do you want to take it to court?"

Karen: "I want to take both of them to court."

At this, all of the officials present agreed that it was Karen's right to go to court, that no one could stop her. But, they argued, the payment would ruin Stanley financially. If he heard about it he would never come back, and the dispute would never be resolved. Besides, only one side of it could be settled at the present time because, while four people were involved, only two of them were present.

After the men consulted privately with Karen, they announced that Melinda would have to pay Karen. They made no statement about what would be required of Stanley. Ordinarily, payment in this kind of dispute would be made between the two women and the two men, but for reasons we discuss below, this was not an ordinary situation. It was not decided whether Karen would charge Stanley in court.

Then the sponsors of the interrupted ceremony spoke about two issues that required immediate settlement. The most vital, because the reputation of the entire village was at stake, was to pay the offended aulu and open the men's house. As long as the aulu could not complete the ceremony and the men's house could not provide hospitality to visitors, the village was an object of derision by outsiders and its residents were shamed. Though the settlement should have included both pigs and shell money from each offender, pigs were in short supply. Therefore, the dispute could be settled with shell currency only.

The second priority was to cool the anger of those who had been offended by the adultery. This could best be done by an interim payment. To that end, K34 should be paid to Louis' representatives pending his arrival, and Melinda was required to make a K30 payment to Karen.

Then the councillor announced the final settlement terms: Melinda and Stanley were each to pay ten fathoms of shell currency (vula) to the aulu (Stanley's father to pay in his absence), Melinda must pay Karen, and Stanley's father would make payment to Sergeant, Louis's father acting as Louis's representative.

Although it was not discussed publicly, this case of adultery was not an ordinary one and it deeply shamed the relatives of Stanley and Louis. As we have discussed in detail elsewhere, the adultery of a man with the wife of a close kinsman (father, brother, son) is viewed as being like incest. It is the behaviour of "people who act like dogs" rather than human being.(14) In addition, the payment of compensation by Stanley's father to Sergeant was highly irregular because Sergeant was classificatory grandfather to Stanley. Men who are members of the same patrilineal group (kambu) SHARE wealth. They do not exchange it.

A last note about Karen and Melinda. When Karen was told that Melinda wanted to marry Stanley, she is reported to have replied, "That's fine. Tell her to come on. My knife is ready!"

Issues: (1) the right of a wife to demand compensation from an unfaithful husband and his lover; (2) whether an aggrieved wife should take her husband to court for adultery; (3) the right of the sponsors of a ceremony to demand compensation from those who disrupted it; (4) adultery between a man and his classificatory father's wife.

Woman's strategy: (1) Wife threatened violence against her adulterous husband and against his lover if she attempted to become her husband's second wife; (2) Wife threatened to take offenders -- her husband and his lover -- to court.

Outcome: The moot decided that the husband's lover must pay compensation to his wife. Fines were levied against the husband and his lover for disrupting the ceremony. The husband's lover did not become his second wife.

Case 2

An impromptu public moot was held to decide whether a young couple should be permitted to divorce. An underlying source of community interest in this case was the fear that the young wife might commit suicide. This case occurred in 1976, shortly after the suicide ofanother young woman (age sixteen), who was rejected by a man who had promised to marry her. Sergeant's classificatory grandson had been implicated in the suicide of this young woman.


Tammy: the wife

Philip: the husband

Sergeant: Philip's father

Summary of the facts: During a quarrel in which she accused him of adultery, Philip beat Tammy and told her he wanted to end their marriage. She spent the night at her parents' house. The next morning, when he went to the gardens, Philip locked the door to their house. In his absence, Tammy broke down the door with an axe and removed her possessions. When he returned home and found the damaged door, Philip began shouting that he and Tammy were divorced.

The noise caused a crowd to gather, including the relatives of both spouses. Philip demanded a divorce. Tammy said she wanted to remain with her mother for a while and return to her husband after he had time to cool down.

Her relatives insisted that Tammy must not run to her mother and sisters every time they fight (that is, when he beats her). She must return to her husband and he must take her back.

Sergeant spoke:

"There is the potential for an endless source of trouble here. The breakup of an established marriage may result in suicide."

Sergeant went on to say that he did not want another woman to commit suicide. To prevent this, he would take the couple to court and they would have to abide by the decision of the magistrate.

After the crowd broke up, Tammy returned to her parents' home. A few days later she quietly returned to live with her husband.

Issues: (1) suspected adultery of the husband; (2) domestic violence; (3) husband's insistence that they be divorced; (4) wife's unwillingness to be divorced.

Woman's strategy: (1) After being beaten by her husband, she went home to her parents. Although they publicly scolded her for leaving her husband over a minor beating, her parents gave her temporary sanctuary from her husband's violence and supported her in opposing divorce. (2) She destroyed property jointly belonging to her and her husband to emphasize her anger. Her act was interpreted as a suicide threat by her husband's father.

Strategy by husband's father: He threatened to take both to court for arbitration of quarrel.

Outcome: After a cooling-off period the marriage was reinstated.

Case 3:

A young woman resists an unwanted arranged marriage. This case occurred in 1981.


Anna: a young unmarried woman;

Kevin: the young man to whom Anna was betrothed by her kin;

Vincent: Anna's lover. Her affair with him terminated her betrothal to Kevin. Anna's parents demanded that she and Vincent marry.

Summary of the facts: Anna's and Kevin's relatives arranged their marriage over her protest. When she would not agree to the marriage, her father beat her. Three weeks later she ran away with Vincent. When they returned she announced that Kevin would no longer want to marry her since she had slept with Vincent. The betrothal was broken and Anna's father demanded that the couple marry and that his relatives pay bridewealth. Vincent's mother made slanderous remarks about Anna's morals and stated that they would pay a small sum for their son having slept with Anna but they would not pay bridewealth. Anna announced that if this were the case she would 'follow her cousin', that is commit suicide.

Shortly thereafter a moot was called by the member of the local government council because of the threat of suicide. Anna's kin demanded the marriage and were silenced by others who insisted that the young couple be asked about their wishes. Both young people said they no longer wished to marry, and the consensus was that they should not be forced. Speeches warned that compelling young people to marry against their will resulted in suicide.

Issues: (1) woman's resistance to arranged marriage;

(2) demands of her parents that her lover marry her versus his mother's insistence that they would not pay brideprice; (3) should a couple be forced to marry against their will?

Woman's strategy: (1) An unmarried woman defied her father and ran away with another man, causing her betrothed to break off the betrothal. (2) She threatened suicide to force her lover's kin to pay bridewealth.

Outcome: The betrothal was broken, the moot condemned Vincent's mother's slander of the girl and the attempt to force the young woman to accept an arranged marriage. There was no forced marriage, but Anna and Vincent married later.

Case 4

A woman and her father's kin quarrelled over the inheritance of her father's property. A major point of disagreement was whether married women have rights in their patrikin group. This case occurred in 1971.


Patsy, the only locally resident child of Avel;

Patsy's father's sister's sons.

Summary of the facts:(15) Customarily, coconuts are matrilineally inherited, so before his death Avel planted coconuts in the name of his children in order that they would inherit a source of cash. Patsy, his only child remaining in the locality, harvested the nuts from the trees, but the harvested nuts were taken by her father's sister's children, made into copra and sold. Patsy demanded that her cousins stop harvesting the nuts from her trees. They replied that the nuts were theirs by matrilineal inheritance. Patsy responded by cutting down some of the trees and announcing that if any more of the nuts were taken she would cut all of them down. Her uterine kin called a public meeting to demand that she renounce her claim to the nuts.

During the meeting she was told by her mother's relatives that, because she was a married woman, she no longer had any rights in her father's kin group or in the property belonging to them. She argued that the nuts she claimed were hers because they had been planted for her and her siblings by her father; he had specifically said that these trees were not to be descend matrilineally. She repeated her threat to cut down all the palms, and she also threatened to take the matter to court for settlement.

The moot ended without a stated consensus. Several months later Patsy was collecting nuts from the palms she claimed and making copra from them.

Issues: (1) the rights of a married woman in her kin group; (2) whether an individual can set aside traditional inheritance rules.

Woman's strategy: (1) She destroyed and threatened destruction of the disputed property. (2) She threatened to take the dispute to court.

Outcome: She exercised her claim in the disputed palms.

Her kin ceased to collect the nuts. She did not take the case to court.

Case 5:

A husband is charged in court for beating his wife. This case occurred in 1985.


Lee: the husband;

Liza: the wife;

Adam: Liza's classificatory father;

Liza's father and paternal uncle.

Summary of the facts: During a marital quarrel Lee beat Liza with a stick. She went to Adam, who was an elected government official, and asked him to support her in charging her husband with assault. He agreed and they took the case to the village court. The magistrate referred it to the district court. When her father and paternal uncle learned this they were worried that the court might sentence Lee to several months in jail. This would have left Liza dependent on her own kin for help with the gardening and other tasks usually done by her husband. Accordingly they attempted to have the charges dropped, arguing that the beating was not a severe one and could be settled by Lee's payment of a few strands of shell money. Adam advised them that matters had gone too far for Liza to back out and the case was taken to district court. The husband was fined K50 and warned that he would be jailed if there was another complaint.

Issue: A husband's abusive beating of his wife.

Woman's strategy: She appealed to her classificatory father who was a government official for support, and to the court system for redress.

Outcome: Her husband was fined for wife beating and threatened with imprisonment if the offense were to be repeated.

Case 6

A woman objects to her husband's plans to take a second wife. This case occurred in 1981.


Patsy and Martin (spouses);

Sue: a widow with whom Martin had a long-term extra-marital affair.

Summary of the facts: Martin had engaged in an affair with Sue, a widow, for years and had fathered two of her children. Village elders met with Martin and insisted that if he intended to continue his sexual relationship with Sue, Martin should marry her. Patsy remarked that she would kill him first. Nevertheless, Martin arranged to pay a small brideprice to Sue's family. When she learned of this, Patsy took a bush knife and chased Martin through the village shouting that she intended to kill him. Shamed, Martin disappeared into the forest. When his family found him a few hours later he was weeping and preparing rotenone poison to drink. His relatives brought him back to the village.

Issue: husband's intention to take a second wife.

Woman's strategy: She threatened extreme violence.

Husband's strategy: attempted suicide.

Outcome: Martin did not marry Sue, nor did he continue his affair with her.

Case 7

This was a dispute over the unequal treatment of co-wives by their husband. This case occurred in 1967.


Mary: Nathan's first wife;

Martha: Nathan's second wife;

Nathan: Husband of Mary and Martha.

Summary of the facts: The co-wife relationship of Mary and Martha was not a happy one. Mary was especially jealous of any attention Nathan paid to Martha and resented any resources used to benefit Martha's children. Because Mary was aggressive and often escalated verbal confrontations to physical violence, Nathan frequently favored Mary in order to avoid trouble. The two women were housed in a duplex with separate entrances and divided by a wall, but while Nathan kept Mary's half of the house in good repair Martha's half was neglected. One day, during a row with Mary, Martha took an axe and destroyed her half of the duplex including the wall separating the two families, exposing Mary to public view and to ridicule. Martha then moved herself and her children into a house belonging to one of her kinsmen, saying that she would return when Nathan had built her a proper house. Mary had no local relatives with whom she could live and was forced to continue living in her half of the demolished house, putting up pandanus mats to make a temporary wall to shelter her from the weather and from the gaze of amused villagers. Over the next months Nathan built two separate houses for his two wives, carefully organizing the construction so that the two dwellings were finished on the same day.

Issue: (1) a husband's neglect of one of his wives; (2) dissension between co-wives.

Woman's strategy: Martha destroyed her property, exposing her co-wife to public view and shaming her husband.

Outcome: Nathan treated his wives equally in the provision of housing.

Case 8

A husband interfered in fighting between his two wives and beat one wife who was ritually forbidden to strike back when she was hit. She attempted suicide in response. This case occurred in 1974.


Mary and Martha (co-wives);

Nathan: their husband.

Summary of the facts: The enmity between Mary and Martha is long-standing and is frequently a source of public amusement. Mary's repeated aggression against Martha, has led Nathan to intervene and beat Mary. On one occasion when Mary fought back, hitting Nathan with a stick, Nathan beat her into unconsciousness. Afraid that he might kill her if she struck him again, Nathan sought a traditional injunction. He called for a visit from a masked spirit-being who lectured the two blindfolded wives, forbidding them to commit further violence against their husband. Violation would require payment of hundreds of fathoms of shell currency to soothe the anger of the spirit. Although the tabu was placed on both wives, everyone knew that the prohibition was directed at Mary who was publicly shamed. Not long after the visit of the spirit, Nathan again beat Mary. Unable to return his blows, Mary went to the beach and drank poison. She was discovered in time for treatment and recovered from her suicide attempt. As a consequence, Nathan did not beat Mary again for over a year. Subsequently, when Mary and Martha fought, other persons (including Mary's own children) intervened on Martha's behalf.

Issue: (1) co-wife and marital violence; (2) use of shame to control a wife's behaviour.

Woman's Strategy: The shamed wife attempted suicide.

Husband's Strategy: He publicly shamed his wife and prohibited his wife's returning his blows.

Outcome: Nathan ceased to interfere when his wives fought and ceased beating his senior wife. Others intervened when Mary's violence against her co-wife became extreme.

Case 9

A wife charges her husband with adultery and prevents him from taking a second wife. This case occurred before 1966.


Mabel, the wife

Gil, the husband.

Summary of the facts: Although Mabel had received compensation payment from Gil for an adulterous affair, he continued to see his lover and was considering taking her as a second wife. Mabel charged him with adultery in court and he was fined. Gil then ended his affair.

Issue: husband's adultery.

Woman's Strategy: The wife charged her husband with adultery in court.

Outcome: A fine was paid by the husband who terminated the affair.

Case 10

An abused wife who wishes to leave her husband seeks support from her relatives. This case occurred between 1971 and 1975.


Dotty, the wife;

Ben, the husband;

Sol, Dotty's second husband in a marriage arranged by her father.

Summary of the facts: Dotty and Ben were married in church but Ben beat Dotty viciously and burned her body with embers. Her father feared that she would be maimed or killed. After a particularly brutal beating, Dotty left Ben and returned to her father's house. She wanted to end her marriage Ben and her father and brothers, who were sympathetic, publicly returned the bridewealth that Ben and his relatives had paid for Dotty and quietly arranged for her remarriage -- on traditional lines -- to Sol, a man recently widowed. Although Sol and his relatives offered bridewealth for Dotty, her father would accept only a token.

Issue: husband's unrelenting abuse of wife.

Woman's strategy: An abused woman obtains support of her male kin in ending an abusive marriage, returning the bridewealth, and remarriage.

Outcome: Woman ends an abusive marriage and enters into a suitable remarriage.

Case 11:

A young woman destroyed her father's property in resistance to an unacceptable arranged marriage. This case occurred in 1964.


Sandy, the betrothed young woman;

Aram, the intended groom;

Mark, Sandy's father;

Summary of the facts: A betrothal was arranged between Sandy and Aram by their fathers and betrothal gifts -- the first instalment of bridewealth -- were paid by Aram's relatives. The relationship between the two affianced persons was stormy and after a fight with Aram, Sandy announced to her father, Mark, that she would not marry Aram under any circumstances. Mark, concerned that breaking the betrothal would shame his kin group, beat Sandy and locked her in his house, hoping that she would become more tractable. Sandy refused to eat and, after a time, broke down the walls of the house where she was confined and ran away, exposing her father to public ridicule. Mark then acquiesced in her desire to end the betrothal, and returned the betrothal gifts. Sandy subsequently married a man of her own choice.

Issue: resistance by a young woman to an unacceptable arranged marriage.

Woman's strategy: She destroyed her father's property, shaming

him into ending the unacceptable betrothal.

Outcome: The betrothal was terminated, the gifts were returned, and Sandy subsequently married a man of her choosing.

Selected Bibliography

Bradley, S.C.
'Attitudes and Practices Relating to Marital Violence Among the Tolai of East New Britain', in Domestic Violence in Papua New Guinea, Law Reform Commission of Papua New Guinea, Boroko 32-71 (1985).

Counts David R. and Dorothy A. Counts, 'The Vula of Kaliai: A Primitive Currency with Commercial Use', OCEANIA vol 41, 90-105 (1970).

Counts, D. and D.
'The Kaliai Lupunga: Disputing in the Public Forum,' in A.L. Epstein (Ed.) CONTENTION AND DISPUTE: ASPECTS OF CONFLICT RESOLUTION IN NEW GUINEA, Canberra: Australian National University Press (1974) 113-151.

Counts, Dorothy Ayers
'Fighting back is not the way: suicide and the women of Kaliai.' AMERICAN ETHNOLOGIST 7 (1980):332-351.

'Revenge Suicide by Lusi Women: An Expression of Power', in D. O'Brien and S. Tiffany (Eds.) RETHINKING WOMEN'S ROLES: PERSPECTIVES FROM THE PACIFIC, Berkeley: University of California Press 71-93 (1984).

'Female Suicide and Wife Abuse in Cross Cultural Perspective', in SUICIDE AND LIFE THREATENING BEHAVIOR 17:194-204 (1987).

'Ambiguity in the Interpretation of Suicide -- Female Death in Papua New Guinea, in D. Lester (Ed.) WHY WOMEN KILL THEMSELVES. Springfield IL: Charles Thomas 87-110 (1988).

'Introduction' and 'Beaten Wife, Suicidal Woman: Domestic Violence in Kaliai, West New Britain' in D.A. Counts (Ed.) SPECIAL ISSUE: DOMESTIC VIOLENCE IN OCEANIA. PACIFIC STUDIES, vol. 13, 1-6 and 151-169 (1990).

'All Men Do It: Wife Beating in Kaliai, Papua New Guinea', in D.A. Counts, J. K. Brown, J. C. Campbell (Eds.) SANCTIONS AND SANCTUARY: CROSS-CULTURAL PERSPECTIVES ON THE BEATING OF WIVES (1992) 63-76.

Counts, Dorothy A. and David R. Counts.
'"People Who Act Like Dogs": Adultery and Deviance in a Melanesian Community', ANTHROPOLOGICA 33: 99-110 (1992).

Modjeska, Nicholas
'Production and Inequality: Perspectives from Central New Guinea', in A. Strathern (Ed.) INEQUALITY IN NEW GUINEA HIGHLANDS SOCIETIES 50-108 (1982).

Sahlins, Marshal 'Poor Man, Rich Man, Big-man, Chief: Political Types in Melanesia and Polynesia, in COMPARATIVE STUDIES IN SOCIETY AND HISTORY, vol. 5, 285-303 (1963).

Scaglion, Richard 'Legal Adaptation in a Papua New Guinea Village Court', ETHNOLOGY vol. 29, 17-33 (1990).

Scaglion, R. and R. Whittingham 'Family Plaintiffs and Sex- Related Disputes in Rural Papua New Guinea', in S. Toft (Ed.), DOMESTIC VIOLENCE IN PAPUA NEW GUINEA, 120-133 (1985).

Strathern, Marilyn
WOMEN IN BETWEEN, New York (1972)

'Introduction' to DOMESTIC VIOLENCE IN PAPUA NEW GUINEA, Law Reform Commission of Papua New Guinea, Boroko 1-13 (1985).


1. 1. See M. Strathern WOMEN IN BETWEEN (1972).

2. 2. 'Poor Man, Rich Man, Big-man, Chief: Political Types in Melanesia and Polynesia, in COMPARATIVE STUDIES IN SOCIETY AND HISTORY, vol. 5, 285-303 (1963).

3. 3. See D.R. Counts and D.A. Counts, 'The Vula of Kaliai: A Primitive Currency with Commercial Use', OCEANIA vol 41, 90-105 (1970) for a discussion of Lusi-Kaliai shell currency and other valuables..

4. 4. For details about dispute settlement in Kaliai see D. Counts and D. Counts, 'The Kaliai Lupunga: Disputing in the Public Forum.' in A.L. Epstein (Ed.), CONTENTION AND DISPUTE: ASPECTS OF CONFLICT RESOLUTION IN NEW GUINEA, 113-151.

5. 5. See N. Modjeska, 'Production and Inequality: Perspectives from Central New Guinea', in A. Strathern (Ed.) INEQUALITY IN NEW GUINEA HIGHLANDS SOCIETIES (1982) 50-108.

6. 6. See pages 36-37 of S. C. Bradley 'Attitudes and Practices Relating to Marital Violence Among the Tolai of East New Britain' and pages 4-5 of "Introduction", both in S. Toft (Ed.) DOMESTIC VIOLENCE IN PAPUA NEW GUINEA (1985) and page 13 of the REPORT OF THE LAW REFORM COMMISSION OF PAPUA NEW GUINEA LAW (1987).

7. 7. See D.A. Counts, 'Introduction' and 'Beaten Wife, Suicidal Woman: Domestic Violence in Kaliai, West New Britain' in D.A. Counts (Ed.) SPECIAL ISSUE: DOMESTIC VIOLENCE IN OCEANIA. PACIFIC STUDIES, vol. 13, 1-6 and 151-169 (1990). Also see D.A. Counts 'All Men Do It: Wife Beating in Kaliai, Papua New Guinea', in D.A. Counts, J. K. Brown, J. C. Campbell (Eds.) SANCTIONS AND SANCTUARY: CROSS-CULTURAL PERSPECTIVES ON THE BEATING OF WIVES (1992) 63-76.

8. 8. For details see D.A. Counts 1980 'Fighting Back is not the Way: Suicide and the Women of Kaliai,' in AMERICAN ETHNOLOGIST, vol 7, 332-351 (1980); D.A. Counts, 'Female Suicide and Wife Abuse in Cross Cultural Perspective,' in SUICIDE AND LIFE THREATENING BEHAVIOR, vol 17(3), 194-204 ; D.A. Counts, 'Ambiguity in the Interpretation of Suicide -- Female Death in Papua New Guinea,' in D. Lester (Ed.), WHY WOMEN KILL THEMSELVES (1988).

9. 9. Studies by Scaglion and Scaglion and Whittingham also report an increasing tendency of women throughout Papua New Guinea to bring their grievances to Village Courts and that these courts are "the single most successful remedy agent in resolving women's grievances." Scaglion considers that the increased use of Village Courts by women is an "particularly encouraging" because "It reflects an increasing equality of genders in the legal realm."' See R. Scaglion, 'Legal Adaptation in a Papua New Guinea Village Court', ETHNOLOGY vol. 29, 17-33 (1990) and R. Scaglion and R. Whittingham 'Family Plaintiffs and Sex-Related Disputes in Rural Papua New Guinea', in S. Toft (Ed.), DOMESTIC VIOLENCE IN PAPUA NEW GUINEA, 120-133 (1985).

10. 10. As Marilyn Strathern notes in her 'Introduction' to DOMESTIC VIOLENCE IN OCEANIA (1985), page 13, violence inflicted by men on women is a class of reactions as well as a class of offences, "and is part of the way people respond and seek remedy for conflict."

11. 11. See, for example D.A. Counts, 'Fighting Back is Not the Way: Suicide and The Women of Kaliai.' AMERICAN ETHNOLOGIST, vol 7, 332-351 (1980); D.A. Counts, 'Revenge Suicide by Lusi Women: An Expression of Power', in D. O'Brien and S. Tiffany (Eds.), RETHINKING WOMEN'S ROLES: PERSPECTIVES FROM THE PACIFIC, 71-93. (1984); D.A. Counts, 'Beaten Wife, Suicidal Woman: Domestic Violence in Kaliai, West New Britain', in D.A. Counts (Ed.), DOMESTIC VIOLENCE IN OCEANIA, PACIFIC STUDIES, Vol 13, 151-169 (1990).

12. 12. The names of all disputants have been changed to protect individual privacy.

13. 13. The kina is the unit of Papua New Guinea currency and in 1985 was roughly on a par with the American dollar.

14. See D.A. Counts and D.R. Counts, '"People Who Act Like Dogs": Adultery and Deviance in a Melanesian Community', in ANTHROPOLOGICA, vol 33, pp. 99-110 (1991).

15. Details of this case are given in D. and D. Counts 'The Kaliai Lupunga: Disputing in the Public Forum', in A.L. Epstein (Ed.) CONTENTION AND DISPUTE (1974) 152-197.

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