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according action administration adoption annulment applied assets Australian Capital Territory Australian courts Bank bankruptcy Cheshire child choice of law claim Commonwealth Conflict of Laws contract Court of Appeal debt deceased decision decree defendant determine Dicey-Morris divorce domicil domicil of origin E.R. Rep effect Ehrenzweig enforcement England English courts English law entitled existence fact faith and credit federal foreign court foreign judgment foreign law full faith governed Graveson Haque held High Court House of Lords husband immovable Indyka issue legal system legislation legitimate lex domicilii lex fori lex loci lex loci celebrationis lex situs liability Lord Wilberforce Lordship Marriage Act 1961 married Matrimonial Causes Act matter movables obligation Ordinance parties person plaintiff polygamous principle Private International Law proceedings proper law provisions Queensland question reason recognition recognized reference relevant resident situated South Wales spouses statute Supreme Court tort trust validity Victoria