Lex fori - Study guides, Class notes & Summaries

International Private Law Cases-Questions And Answers 100% Verified Winkworth v Christie - ANSWER-Issue: exclusion of foreign law Test: would the application of the foreign law be contrary to public policy? Facts: works of stolen art from England to Italy. They were sold to a good faith buyer and then auctioned in England. Italian law was the lex causae and the lex situs. Held: English law was not invoked because there were only some English connecting factors. Hammer & Sohne v HWT Rea...

LJU4804_PORTFOLIO 2021. LJU4804 - Private International Law. As above the lex domicilii matrimonii is interpreted as the domicile of the husband at the time of conclusion of the marriage. It has been argued that the reason for this interpretation stems from when a wife automatically took her husband’s domicile upon marriage. It was argued that this rule prevents a husband from changing his domicile after marriage to secure a property advantage at the expense of his wife. However, this rul...