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Renvoi in private international law

Doctrine asking whether a reference to foreign law includes that system’s conflict rules, possibly sending the matter back or onward.

Renvoi arises when the forum’s conflict rules refer a matter to foreign law and the question is whether that reference includes only substantive rules or also the foreign conflict-of-laws rules. If the foreign rules refer back to the forum, this is remission; if they refer to a third legal system, this is transmission. Swiss private international law uses renvoi selectively and with attention to predictability, party expectations, and the purpose of the connecting rule. It is especially relevant in status, family, and succession contexts.

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