Va. Code » Title 20. Domestic Relations » Chapter 6. Divorce, Affirmation and Annulment
Virginia Code

Va. Code Ann. § 20-98 (2026)

Repealed

✓ laws through the 2026 session (checked Sept. 2026)
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Repealed by Acts 1977, c. 624.

Notes of Decisions
Cited in 7 cases, 1954–1996 · leading case: Colley v. Colley, 129 S.E.2d 630 (Va. 1963).
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Colley v. Colley, 129 S.E.2d 630 (Va. 1963). · cites it 4× “The complainant testified that she had sexual relations with the defendant in Prince William county within the week prior to their going to Louisa county on December 21, 1960, and that she also had such relations with defendant in January, 1961, in Louisa county, and that was…”
Netzer v. Reynolds, 345 S.E.2d 291 (Va. 1986). · cites it 2× “In Colley , we construed the word “cohabit,” as used in the divorce venue statute (then Code § 20-98, repealed by 1977 Acts, c. 624, replaced in pertinent part by present Code § 20-96 (B)) to mean “having dwelled together under the same roof with more or less permanency .”
Rochelle v. Rochelle, 302 S.E.2d 59 (Va. 1983). · cites it 2× “3 The venue provisions of Code § 20-98 were, and still are, jurisdictional, but relate only to suits for divorce, affirmation of marriage, and annulment.”
Westfall v. Westfall, 82 S.E.2d 487 (Va. 1954). “Code, § 20-98. On February 9, 1953, a decree was entered referring the cause to a commissioner in chancery to ascertain whether the necessary grounds existed to give the court jurisdiction and whether the defendant wife had deserted and abandoned the plaintiff “without…”
DeRyder v. Metro. Life Ins. Co., 145 S.E.2d 177 (Va. 1965). “DeRyder could have established a legal residence in any one of the stated places, and under the provisions of § 5105 (now § 20-98) he could have instituted suit and obtained a divorce since his wife, Jennie, was a nonresident of this State.”
Naugle v. Naugle, 3 Va. Cir. 250 (Alexandria Cir. Ct. 1984). “225 (1963), the court reviewed its earlier decision in Tarr and concluded that for purposes of the venue statute (§ 20-98, now § 20-96, Virginia Code) the word "cohabit" should be given its literal meaning of having dwelled together as husband and wife under the same roof with…”
Buck v. Robertson, 39 Va. Cir. 447 (Richmond County Cir. Ct. 1996). “The Court said: With respect however to § 20-98 of the Code prescribing the venue of divorce suits, the word “cohabit” should be given “its literal meaning of having dwelled together under the same roof with more or less permanency” .”
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