Renvoi (or the foreign Court theory) means if we are referred to the law of a foreign Court we must put ourselves in the position of that foreign Court thus the Court may either be referred to our law or to our law including our choice of law rules. Hence a matter may be returned to be determined by the foreign law. The High Court recently confirmed this position in the case of Neilson (2005) however in Paulin (1950) confirmed it does not apply in cases of family provision matters. Family provision cases are dealt with at the domicile of the applicant. The rule is however applied for essential validity of wills and intestate succession.