internal law of the forum

law [of the casue] to be applied by the forum

law of party's domicile

law of the country where a marriage celebrated

law of the country where contract deemed to have been formed

law of country where contract to be performed

law of country where legal act takes place

law to which a legal act/ transaction has the most connection

law of a person's domicile

law of the country where property situated

law of country where a delict performed

law used to determine rights in succession

REGULATION re jurisdiction, recognition, and enforcement of judgments re matrimonial and PR matters

REGULATION re jurisdiction, recognition and enforcement of judgments in CIVIL & COMMERCIAL matters

Classification-
collection of tax - no!
Assisting in investigation -Yes!

proof of foreign law provided by...

Judicial knowledge of Scots law and Scots IPL law assumed bu Scots ct, but UKSP

Foreign law is a Q of

where parties ignore FL aspect in pleadings

if D has not raised FL issue in pleadings but later feels it would be advantageous...

Bonnor v Balfour Kilpatrick

Pryde v Proctor & Gamble

gift inter vivos so
lex situs, or
donatio mortis causa so lex successionis

Re Korvine's Trust

incapax to contract creates international invalidity

onus of proving DoO changed to DoC

Jamaican colonist; Scots roots rtns when slavery abolished; wife dies soon after; daughter could not demo F was Scots domd as he hadn't made up mind (W's Dom follwed H's)

Art 5(1) (Brussels I) only works where single place of performance

Brussels I Art 5(1)

Brussels I Art 2

Brussels I on contract

Brussels I on consumer contracts

Brussels I on property

Brussels I on prorogation

Brussels I on appearance by Def

Brussels I on lis pendens

only possible to have one one residence quoad Brussels I; 10% of time spent in England does not qualify

Cherney v Deripaska

enforced residence does not equal substantial connection viz s41 CJJA1982

dom determined at time summons signed by Sh Clerk (Scot) or issuing of the writ (Eng)

principal extra-EU IPL Convention?

BI and Lugano II Art that refers to suing in the MS of any one of the defenders

Swiss dom of a multi party provided jurisdiction under Lugano II (extra-EU)

Single place reqd to justify jurisdiction quoad place of performance of contract viz BI A5(1) (or LII): case?

where more than one place of provision of service (air travel), ct to look for most significant linking factor

even where a business has detailed spec of goods to be supplied by supplier, still contract for sale of goods, so place of delivery viz BI A5(1)(b) indent 1 relevant

Contract for provision of services governed by BI A?

contact for sale of goods governed by BI A?

where services and sale of goods

BI Art 23 deals with

BI Art 27 deals with

conflict between A23 and A27 BI: priciple and case?

Enforcement of judgements; Ct addressed does not revist Ct of Origin judgement unless

Marriage: criteria viz
Hyde v Hyde & Woodmansee

2 principle questions re validity of marraige

essential validity of marriage relates to questions of?

German national domd in Eng; 1st wife died and wanted to marry her sister in Germany; because he was domd in Eng immediately prior to marriage, even though ok by German law, invalid in Eng

validity of Marriage in Scotland governed by

essentail validity of marraige determined by ct of dom imed prior to marriage; Jewish Egypian uncle/neice married in Egypt:

Q of formal validity of marriage determined by lex loci celebrationis, case?

divorce proceedings re French couple in England dismissed as no formal validity of French marraige, case?

German domd in Eng imd prior to attempt to marry his late wife's sister in G: law of ? validity, and governed by ?