When it is determined that a court has authority, the next question to be asked is whether the

conflict is characterised by the laws of private international law and whether the rules of law are to
be chosen. It is also erroneously seen that after this is finished, the role of the judge has come to a
logical end after completion of the characterisation, and little more remains to be done except
applying the rule chosen. The judge would have followed British law in that respect if it had been
English law that is the law chosen, and he would have taken equal steps if it had been Indian law
that was the law chosen.

Therefore the law of distribution found in the Administration of the Estate Act 1925 must be
followed when an individual dies intestatal residence in England and leaves mobile there. The laws
of private international law cannot be further considered. Although if the relevant law is
international, the case could be more difficult than if the internal law of the lex fori1 state is
determined at a local level.

A British subject Mr. A has passed away, for example, how his property be circulated in England,
who was intestate, domiciled in Italy and an English Court was to decide the case. The cause of
action in England has formed the jurisdiction of the English court. The domestic legislation relevant
to this case is the I925 Administration of the State Act, but the British private foreign law is here
applicable as Mr. A has his domicile in Italy. In that case, it says the domicile law shall apply and
that the Italian law should apply in this case because A was domiciled in Italy.

The question of the essence of the Italian law that may be applicable to this dispute—Italian law,
such as domestic legislation, or Italian private international law—is more complicated, however.
This difficulty is because Italian domestic law states that Italian law should apply only on the basis
of nationality, and that the deceased was a British subject, so that Britain's law should apply. In
accordance with British domestic law, his succession issue was to be resolved by British Internal
Law.

The third option is to use what is known as the foreign court principle, also known as the English
doctrine of renvoi, or the doctrine of double renvoi or absolute renvoi. When the relation is from A
to B and then from B to C, it is called a complete renvoi. The testamentary dispositions of a British
subject who dies domiciled in Belgium and leaves properties in England raises a doubt. A Belgian
judge familiar with this issue would be referred to English law's rules of private international law,
but he would also discover that English law had remitted the case to him. As a result, evidence must
be shown in the English proceedings to prove what the Belgian judge will really do. He could
recognise the remission and use his own internal law, or he could refuse it and use English Private
International Law.

1 The law of the country in which an action is brought.