3.4 Renvoi: Partial and Total Renvoi

The doctrine: the "send-back" — the conflict rule points to a foreign law; the foreign law's OWN conflict rule points BACK (or on to a third) — the referral's problem: apply the foreign's domestic law or the foreign's whole law (including its conflict rules)? The kinds: (1) remission (the send- BACK: the foreign conflicts point home → the forum's law applies); (2) transmission (the send-ON: the third law applies); the partial renvoi (the remission accepted (the English craft: the whole foreign law (conflicts included) → the send-back honoured — the Anisminic-era's doctrine)); the total renvoi (the full referral's iteration craft — the ping-pong's theoretical completion (the rare adoption)); the rejection (the majority: the foreign DOMESTIC law only (the conflict rules ignored — the renvoi refused (the German-and-many's rule))).