Partial Renvoi

The Question of Succession to movable of an Indian

National Domiciled in Italy

India court shifts the case on
application of law of Italy
(recognising its conflict of
law rules )
Lex Domicilli
Italian court applies its law
of conflict and shifts back the
matter to the application of
law according to nationality
i.e India

The Indian Court accepts back the

matter from Italy, but treat it as
reference to domestic rules.
Applying the Indian Domestic law only
 Total Renvoi

The Question of Succession to movable of an Indian

National Domiciled in Italy

India court shifts the case Italian court applies its law
on application of law of of conflict and shifts back
Italy (recognising its the matter to the
conflict of law rules ) application of law
according to nationality i.e
Lex Domicilli India

The Indian Court then Here Italy accepts the

again shifts the matter to renvoi and applies the law
Italian Law of France.
Example

In Re Annseley
British National Women, domiciled in France died having made her will
The Will was valid under English law but Invalid under French Law as she did not
left two thirds of estate to her children.
Under English law she has acquired French Domicile, but under French law she
was not regarded French domicile as French govt. had not issued an authorization
certificate.
The French Court applied the whole French Law including law of conflicts, under
which English law was applic