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Part VI The Law of Property, Ch.33 Matrimonial Property

J J Fawcett LLB, PhD, Solicitor, J M Carruthers LLB (Hons), Dip LP, PhD, Solicitor
Edited By: Sir Peter North CBE, QC, MA, DCL, FBA

From: Cheshire, North & Fawcett: Private International Law (14th Edition)

James J Fawcett, Janeen M Carruthers
Edited By: Sir Peter North (Consultant Editor)

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From: Oxford Legal Research Library (http://olrl.ouplaw.com). (c) Oxford University Press, 2023. All Rights Reserved.date: 17 July 2024

Matrimonial property — Immovables — Movables — Law of the country of domicile
The problem that confronts us in this chapter is how to determine what system of law regulates the rights of a husband and wife in the movable and immovable property which either of them may possess at the time of marriage or may acquire afterwards. Important consequences may ensue depending on which law is chosen. For instance, the result of choosing one particular legal system may be that the property of the wife passes entirely to the husband, as was substantially the case in England prior to 1883. Again, if an Englishwoman marries a Belgian and Belgian law is...
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