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IN RE C0IIN UJU IUIUIU
IN RE Ross
NOIE AI CHARACTERIZATION THE INCIDENTAL QUESTION AND RENVOI
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according action adopted alleged apply authority Bank beneﬁt bona vacantia child cile circumstances claim Conﬂict of Laws contract contrary Court of Appeal decided decision decree of nullity defendant determined Dicey diﬂiculty divorce domi domiciled in England effect enforce English courts English law entitled fact ﬁnd ﬁrst foreign country foreign court foreign judgment foreign law France French law governed ground held House of Lords husband immovables INDYKA intended international law issue jurisdiction land law of England law of France legitimate lex domicilii lex fori lex loci lex loci celebrationis lex loci contractus lex situs Lordships marriage married matter ment movable oﬂice Ontario opinion parties person petition petitioner plaintiff polygamous principle proceedings proper law provisions question reason recognised recognized regarded Reneville resident rule Scotland settlement ship status suﬂicient testator testator’s tion trust valid void voidable voidable marriage wife wife’s