Domicile as deciding factor

A Mumbai-born engineer moves to Dubai on a five-year contract, marries there, and dies without a will while owning a flat in Navi Mumbai and savings in a Dubai bank. Whose law decides who inherits: India's, the UAE's, or the law of the country of his passport? Private international law answers by asking where he was domiciled. This topic explains why family law, more than any other branch of the subject, keeps coming back to that one word.

In two minutes

Domicile is the legal connection between a person and a country whose law governs his personal status, and in family matters it is the main connecting factor that tells a court which system of law to apply.

The rest of this chapter

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