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1. See Anton, pp275-279.
2. See Part XVIII.
3. There is an extensive international literature on this subject which seems to give rise to more difficulty in practice in countries with community property regimes. See eg Regimes Matrimoniaux, Successions et Liberaliffis: Droit Intemational priv6 et Droit compar6 (Verwilghen ed 1979). There is a Hague Convention on the Law Applicable to Matrimonial Property Regimes which was concluded on March 14, 1978 but which, as at March 22, 1989, had been ratified by only France and Luxembourg. It makes the governing law, in the absence of express agreement and subject to some important and quite complex qualifications, the law of the State in which both spouses establish their first habitual residence after marriage. (Art 4).
4. See Anton, pp584-589; Dicey and Morris, pp1066-1067; Cheshire and North, p864; Clive, p335.
5. Anton, pp576-584; Dicey and Morris, pp1053-1058; Cheshire and North, pp869-872; Clive, pp335, 337.
6. Dicey and Morris, p1068; Cheshire and North, p868; Clive, p336.
7. See eg Dicey and Morris, p 1066; Cheshire and North, p864. The Married Women's Property (Scotland) Act 1881 used to contain a reference to the husband's domicile in sl but this has now been repealed.
8. See Anton, p584.
9. Cf Anton, p586. (Where, in relation to moveable, no immutable regime has been established by express contract or operation of law, the 1ogic of the present law suggests that the proprietary relationships of the spouses must simply be assimilated to those of unmarried persons".)
10. Welch v Tennant (1891) 18 R (HL) 72.
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