In this connection I would like to refer to the dictum of Scrutton L.J. in Casdagli v.

Casdagli n(2) , where he says:

"Practical and theoretical difficulties arise from the fact that, while England decides questions of status in the event
of conflict of laws by the law of the domicil, many foreign countries now determine those questions by the law of the
nationality of the person in question. Hence it has been argued that if the country of allegiance looks to or sends
back the decision to the law of the domicil, and the country of domicil looks to or sends back (renvoyer) the
decision to the law of nationality, there is an inextricable circle in 'the doctrine of the renvoi' and no result is reached.
I do not see that this difficulty is insoluble. If the country of nationality applies the law which the country of domicil
would apply to such a case if arising in its Courts, it may well apply its own law to the subject-matter of dispute,
being that which the country of domicil would apply, but not that part of it which would remit the matter to the law of
domicil, which part would have spent its operation in the first remittance. The knot may be cut in another way, not
so logical, if the country of domicil says, 'We are ready to apply the law of nationality, but if the country of nationality
chooses to remit the matter to us we will apply the same law as we should apply to our own subjects.'" This dictum,
in effect, approves of the decision of such matters in accordance with the law as interpreted and administered by
the Courts of the country of domicil.

I have I think now dealt with all the relevant cases. In addition to them my attention has been called to a number of
articles by international jurists. There is an acute conflict between the various authors on the question, and so far
as the English writers are concerned, they seem to be fairly equally divided. I should also add that in the course of
the argument my attention was called to the report of the American case referred to by Russell J. in his judgment in
In re Annesley n(1) - namely, the case of In re Tallmadge. In re Chadwick's Will. n(2) The decision is that of the
Surrogates Court, New York County. The judge of that Court goes through most of the authorities to which I have
referred, and comes to a conclusion opposite to that at which I have arrived. For the reasons I have endeavoured
to express in this judgment, I think his decision is not in accord with the English authorities.