This chapter considers judicial attitudes towards marriage and immigration before 1997, including marriages believed to have been entered into for immigration reasons. It shows that the judiciary was largely indifferent to these before the era of mass non-white Commonwealth immigration. When cases involving New Commonwealth immigrants started to come before the courts, judicial attitudes became more complex and inconsistent. This chapter argues that there was, at least in the early stages, some sympathy. However, this came to be tempered by anxiety about non-white immigration, albeit only occasionally overtly expressed, and a hardening of attitude. The courts did not check and often assisted government and administrators in ensuring that the ‘primary purpose’ rule applied to marriages that were acknowledged not to be a sham.