Say the ratio out loud before you open Reasoning — recalling it unprompted is exactly what the exam pays for.
Why it matters
It is the twin of Forgo. The same machinery of partial or single renvoi is run, and the outcome is the opposite — the claim succeeds instead of failing. That is why the pair is worth more than either case alone: together they prove that renvoi has no inherent tendency and that everything depends on the content of the two internal laws.
Facts
A British national domiciled in Italy died, leaving movables and immovables in Italy and movables in England. Her will was valid by English law but invalid by Italian law, because she had not left half her property to her son.
Held
The English court applied English law and upheld the will.
Reasoning
Step one — the forum's own conflicts rule. English private international law referred the question to the law of her domicile, Italy.
Step two — read the reference in the wide sense. The reference to Italian law was taken to include Italian conflicts rules, not merely Italian internal law. That step is the whole of renvoi.
Step three — follow the foreign conflicts rule. Italian conflicts law referred the matter to the law of the nationality, England. That is a remission — a reference back to the forum.
Step four — accept the remission and stop. The English court accepted the reference back and applied English internal law, under which the will was good. It did not go on to ask what an Italian judge would have done with the English reference back; that further question is the mark of total renvoi.
Exam use
It opens: What is renvoi? Explain with cases — as the second illustration of partial renvoi, immediately after Forgo.
Use the pair to make the evaluative point. In Forgo the reference back deprived remote collaterals and the estate escheated to the State; here it saved a will that the law of the domicile would have struck down. The doctrine is defended as promoting the reasonable expectations of the parties, and the results show that it does so only by accident.
Keep it apart from total renvoi. Collier v. Rivaz and Re Annesley run a different operation — the forum decides as a judge in the foreign country would decide, including that country's own attitude to renvoi — and they too reach opposite results, but for reasons lying in the foreign doctrine rather than in English law.
It does not decide anything about renvoi in contract, where the doctrine is excluded: NTPC v. Singer Company holds that the proper law means the substantive principles of the chosen domestic system and not its conflict of laws rules.