renvoi

The renvoi principle in law refers to a situation where a court, when deciding which law to apply in a case involving foreign elements, encounters a foreign law that itself directs back to the court's own law or to a third country's law. This raises the question of whether the court should accept this "send back" or referral.1

Many legal systems do accept renvoi, applying their own law when the foreign law refers back to it. However, not all legal systems use renvoi, and even those that do may exclude it in certain types of cases, such as tort and contract cases within the EU. The core issue is determining whether a reference to foreign law includes that law's own conflict-of-laws rules.1