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abroad according adopted apply Bank bill British capacity Ch.D choice of law claim common law Conflict of Laws contract Court of Appeal creditor debt debtor decision decree defendant determined Dicey & Morris divorce doctrine domicil of origin domiciled in England E.R. Rep effect enforce English court English law fact foreign country foreign court foreign judgment foreign law France French law governed granted ground held House of Lords husband Ibid immovables Indyka infra instance intention issue judge jurisdiction land legal system legitimate lex causae lex domicilii lex fori lex loci celebrationis lex loci contractus lex situs liability Lloyd's Rep marriage married Matrimonial Causes Act matter movables nationality nullity obligation parties plaintiff polygamous principle private international law proceedings proper law propositus question recognition recognized regard relevant residence rule sovereign status supra testator tion tort transaction Trusts void wife