Au Revoir to Renvoi?
C.J.S. Knight has written a casenote in the Conveyancer and Property Lawyer on the High Court decision in Iran v Berend (Conv. (2007) November/December Pages 564-571). Here’s the abstract:
Discusses the Queens Bench Division decision in Iran v Berend on whether renvoi has a place in choice of law cases concerning title to moveable property, in particular whether in a case concerning title to a fragment of limestone relief originating in ancient Persia, bought in New York by a resident of France and sent to England to be auctioned the English court was bound to apply French private international law rules or whether the dispute fell to be determined by reference to French domestic law. Considers the purpose of the lex situs rule in conflict of law cases.
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