Abstract In 2018, the British Overseas Territory of Bermuda revoked the right to marry for same-sex couples. In a judgment that reconceives the relationship between sexual orientation and religious freedoms, the Bermuda Supreme Court and Court of Appeal found this revocation to be unconstitutional. I explore the political and legal context in which same-sex marriage was granted and then revoked in Bermuda. I also consider the Bermuda Courts’ judgments in light of the subsequent judgment of the United Kingdom’s Supreme Court in Steinfeld, among others. While there was an assumption from both the Bermuda and United Kingdom Governments that the revocation provision was compatible with the European Convention on Human Rights, I argue that this underestimates the significance of the distinction between declining to recognise a right to same-sex marriage and revoking a right that has already been exercised. While the European Court of Human Rights has not yet found the absence of same-sex marriage to be a violation of Article 12 of the Convention, I argue that the revocation of a right to marry between same-sex couples that had been recognised in accordance with national law changes the terrain on which the Convention arguments would be made.

中文翻译：

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“匆忙结婚……”：百慕大（部分）废除同性婚姻

摘要 2018年，英国海外领土百慕大撤销了同性伴侣的结婚权。在重新考虑性取向与宗教自由之间关系的判决中，百慕大最高法院和上诉法院认为这种撤销是违宪的。我探讨了在百慕大批准和撤销同性婚姻的政治和法律背景。我还考虑了百慕大法院的判决，其中包括英国最高法院在 Steinfeld 的后续判决。虽然百慕大和联合王国政府都假设撤销条款符合《欧洲人权公约》，我认为这低估了拒绝承认同性婚姻权利和撤销已经行使的权利之间区别的重要性。虽然欧洲人权法院尚未认定同性婚姻的缺失违反了公约第 12 条，但我认为撤销已被承认的同性伴侣之间的结婚权随着国内法的改变，《公约》的论点将发生变化。