renvoi

1. (law) A situation in which a court, tasked with deciding which state's law should apply to a case, decides to apply the law of the forum, based on the determination that a court from another involved state would also apply the law of the forum.Examples: "As has been shown, the renvoi, if logically carried out, involves a perpetual deadlock. But both England and America try the validity of a will of personalty by the law of the testator's last domicil."; "The application of renvoi in matters of personal status, family relationships and succession involves mainly conflicts between the national law and the law of the domicile, but it may also comprise a renvoi from the personal law to the lex rei sitae, notably in matters of matrimonial property and succession. This may result in a partial renvoi, e.e. when immovables forming part of a succession are situated outside the country, the law of which governs the succession as the personal law."; "However, it could be alternatively argued that there is a general principle at common law that renvoi does not apply in relation to what are termed “obligations” for the purposes of private international law."countableuncountable