Once it is decided that a court has jurisdiction, how the issue before it is to be characterised in terms of private international law and what choice of law rules are applicable, it might be thought that the judge’s task was reaching its conclusion. Nothing remains for him to do but apply the chosen law. If this is English law there is no doubt that what he is required to do is to give effect to English internal law. Thus, where a person dies intestate domiciled in England leaving movables here the rules of distribution contained in the Administration of Estates...
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