VVC v JRM clarifies how South African law treats couples who first marry under customary law and later conclude a civil marriage. The Court held this is one continuous marriage, not a new one. Rights and obligations from the customary marriage continue and property accumulated remains protected. Spouses cannot informally change proprietary rights; any change to the matrimonial property system requires court approval under section 21 of the Matrimonial Property Act. Interpreting section 10(2) of the Recognition of Customary Marriages Act with the MPA, the judgment advances equality, dignity, the protection of property rights and legal certainty, protecting vulnerable spouses and creditors.