of married women was common across European countries, through marriage laws giving legal authority to the husband, as well as through marriage bars. In 1978, the Council of Europe passed the Resolution (78) 37 on equality of spouses in civil law. Switzerland was one of the last countries in Europe to establish gender equality in marriage, in this country married women's rights were severely restricted until 1988, when legal reforms providing for gender equality in marriage, abolishing the legal authority of the husband, come into force (these reforms had been approved in 1985 by voters in a referendum, who narrowly voted in favor with 54.7% of voters approving). In the Netherlands, it was only in 1984 that full legal equality between husband and wife was achieved: prior to 1984 the law stipulated that the husband's opinion prevailed over the wife's regarding issues such as decisions on children's education and the domicile of the family. In the United States, a wife's legal subordination to her husband was fully ended by the case of Kirchberg v. Feenstra, , a United States Supreme Court case in which the Court held a Louisiana Head and Master law, which gave sole control of marital property to the husband, unconstitutional. There have been and sometimes continue to be unequal treatment of married women in various aspects of everyday life. For example, in Australia, until 1983 a husband had to authorize an application for an Australian passport for a married woman. Other practices have included, and in many countries continue to include, a requirement for a husband's consent for an application for bank loans and credit cards by a married woman, as well as restrictions on the wife's reproductive rights, such as a requirement that the husband consents to the wife's acquiring contraception or having an abortion. In some places, although the law itself no longer requires the consent of the husband for various actions taken by the wife, the practice continues de facto, with the authorization of the husband being asked in practice. Although dowry is today mainly associated with South Asia, the practice has been common until the mid-20th century in parts of Southeast Europe. Laws regulating marriage and divorce continue to discriminate against women in many countries. In Iraq husbands have a legal right to "punish" their wives, with paragraph 41 of the criminal code stating that there is no crime if an act