to privately, while in other areas, agreements related to the marriage have to be rendered in writing to be enforceable. In the absence of agreement, a contested divorce may be stressful to the spouses. In some countries, when the spouses agree to divorce and to the terms of the divorce, it can be certified by a non-judiciary administrative entity. The effect of a divorce is that both parties are free to marry again if a filing in an appellate court does not overturn the decision. Contested divorce Contested divorces mean that one of several issues are required to be heard by a judge at trial level—this is more expensive, and the parties will have to pay for a lawyer's time and preparation. In such a divorce the spouses are not able to agree on issues for instance child custody and division of marital assets. In such situations, the litigation process takes longer to conclude. The judge controls the outcome of the case. Less adversarial approaches to divorce settlements have recently emerged, such as mediation and collaborative divorce settlement, which negotiate mutually acceptable resolution to conflicts. This principle in the United States is called 'Alternative Dispute Resolution' and has gained popularity. At-fault divorce Before the late 1960s, nearly all countries that permitted divorce required proof by one party that the other party had committed an act incompatible with the marriage. This was termed "grounds" for divorce (popularly called "fault") and was the only way to terminate a marriage. No-fault divorce is available in Australia, New Zealand, Canada, the United States and other Western countries. Fault-based divorces can be contested; evaluation of offences may involve allegations of collusion of the parties working together to get the divorce, or condonation by approving the offence, connivance by tricking someone into committing an offence, or provocation by the other party. Contested fault divorces can be expensive, and not usually practical as eventually most divorces are granted. Comparative rectitude is a doctrine used to determine which spouse is more at fault when both spouses are guilty of breaches. The grounds for a divorce which a party could raise and need to prove included 'desertion,' 'abandonment,' 'cruelty,' or 'adultery.' The requirement of proving a ground was revised and withdrawn by the terms of 'no-fault' statutes, which became popular in many Western countries in the late 1960s and early 1970s. In 'no-fault' jurisdictions divorce can be obtained either