CONFLICT OF LAWS-RENVOI DOCTRINE

Authors

Abstract

H, an Englishman, married W in England. On separation H acquired a domicil in Germany. A child was thereafter born to Y, a woman with whom H was living in Germany. H subsequently divorced W in Germany and married Y. Whether the child was legitimate determined whether H had validly exercised a power of appointment in an English settlement. Held, legitimacy is to be determined by the law of the domicil, including its rules of private international law. Germany, referring the matter to English law, found a remittance which Germany accepted and applied German municipal law. The child, by such law, is legitimate. In re Askew, [1930] 2 Ch. 259.

Recommended Citation

CONFLICT OF LAWS-RENVOI DOCTRINE, 29 Mich. L. Rev. 627 (1931).
Available at: https://repository.law.umich.edu/mlr/vol29/iss5/16