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Young 1900 2 Ch 339 306
Berchtold 1872 7 Ch App 192 273
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abroad according acquired a domicile action adoption applied bill capacity Cheshire choice of law claim common law contract decided decision decree of nullity defendant determine Dicey died domiciled doctrine domicile of choice domicile of origin domiciled in England E.R. Rep effect enforced English court English law English private international essential validity fact foreign country foreign court foreign decree foreign judgment foreign law foreign sovereign formal validity French law German ground held husband immovables infant intention judicial law governs law rule lex causae lex domicilii lex fori lex loci celebrationis lex loci contractus lex patriae lex situs married Matrimonial Causes Act monogamous movables obtained parties petition plaintiff polygamous marriage principle private international law proceedings proper law property in England provides public policy question recognised in England reference refused regarded relating Reneville renvoi resident in England Scotland status tion tort United Kingdom void voidable marriage wife writ