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according action adopted annulled apply assets authority Bank capacity child cile circumstances claim Conflict of Laws contract Court of Appeal creditors damages debt decided decision decree defendant determined Dicey divorce domi domicile of origin domiciled in England effect enforce English courts English law entitled fact favour foreign country foreign court foreign judgment foreign law French law governed ground held House of Lords husband immovable intention Inverclyde Italian judge jurisdiction land law of England law of France legitimate lex domicilii lex fori lex loci lex loci celebrationis lex loci contractus lex situs liability Lordships marriage married matter ment movables nullity opinion parties person petition petitioner plaintiff principle proceedings proper law provisions question reason recognised recognized referred regard Reneville resident respondent rule Scotland settlement ship status suit testator testator's tion tribunal Trusts valid void voidable voidable marriage wife