Marriage is in every view the most important institution of human society, it involves the most valued interests of every class; awakens the thoughts and engages the care of nearly every individual; and how it may be entered into, or how dissolved, or what is the collateral effect of a dissolution, is a matter of almost constant legal inquiry and litigation. The label “heart balm” was used during the first wave of legislative abrogation to satirize the notion that money damages could make the heart feel better. Today, it is common practice to award money damages when a plaintiff has suffered loss of love and affection. However, a few “heart balm” torts persist, however, and occasionally surface in modern cases. Although actions arising from alienation of affection or from breach of promise to marry are barred. The statutes does not preclude an action for return of things given in reliance of false and fraudulent representation nor affect rights and duties determinable by common law principles. It is now common practice for people to sue for heart balm torts under the guise of tort actions such as, breach of promise, emotional distress, etc.