Renvoi

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Definition

A conflict of laws doctrine where a court applies another jurisdiction's conflict of laws rules rather than its substantive law—because sometimes even the rules about rules conflict.

Example Usage

The court applied the doctrine of renvoi and looked to French conflict law instead of French substantive law.

Origin

French word meaning 'return' or 'sending back'

Fun Fact

Renvoi creates infinite loops in theory (State A says use State B's law, State B says use State A's law) but courts have largely rejected it to avoid absurdity

Source: Conflict of laws terminology

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