acts three times, each for a period of one year, in 1977, 1987, and 1995. At the time of the first special act in 1977, 4577 same name/common ancestor couples became legally married. In 1988 the number increased to 12,443, and by 1996, it had reached 27,807. Some estimate that the actual number is as high as 200,000 couples, nearly 2 percent of all married couples in South Korea. The children born of such marriages were, legally, out-of-wedlock. They were not eligible for national health insurance and were discriminated against in matters of inheritance and property rights. The Korean Legal Aid Center for Family Relations established a special report and counselling facility for couples subject to Article 809. Article 809 has been much criticised by family lawyers and the Korean Law Association on the ground that it infringes on the freedom of choice in marriage, and that it reinforces traditional paternalism. Constitutional case On 20 May 1995 the Family Court of Seoul referred to the Constitutional Court the case brought forth by eight couples who asked the court to evaluate the constitutionality of Article 809. They argued that the code violated the "right to the pursuit of happiness" and the "right to family life" guaranteed by articles 10 and 36, respectively, in the "Chapter 2. Right and Duties of Citizens" of the Constitution of the Republic of Korea. Two years later, the Constitutional Court ruled 7 to 2 against Article 809. The court held that Article 809(1) was incompatible with the Constitution and that if the National Assembly did not amend it by 31 December 1998, it would become null and void, commencing on 1 January 1999. The court declared that until the National Assembly amended the article, other courts and government agencies, including local governments, should not apply it. In accordance with this declaration, the Supreme Court of Korea announced new family registration procedures for the applications filed by couples sharing surname and ancestral home before the revision. In addition, parts of the Rules of the Supreme Court on Family Register that prohibited the registration of marriage between these couples (Rule No. 172) and that concerned mistaken registration (Rule No. 176) were abolished. The majority opinion stated that:the law against marriages between members of the same agnatic lineage descendants violates the dignity of human beings and the right to the pursuit of happiness as guaranteed by the Constitution as