This scholarly work examines whether the renvoi, a concept from Civil Law, should be part of the common-law approach to private international law. It presents the premises, different views, and the authority that influence how courts decide where a deceased person’s movables should be distributed when multiple jurisdictions might apply.

Defines the renvoi and explains its origin in private international law.
Discusses how the law of the situs and the law of the domicil interact in determining succession.
contrasts internal law and private international law and shows how courts choose which to apply.
Offers a reasoned look at principles and authorities that shape the doctrine in practice.

Ideal for readers of law who want a clear, logically structured discussion of a complex topic in private international law.

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