ourts have continually to struggle with the
difficulty of selecting his domicile from among the various places in
any of which he may be said to reside.

Since the beginning of the 19th century most of the leading continental
states have unified their internal laws; and attachment to a province by
domicile having thus become an unnecessary consideration, they have
adopted political nationality as the criterion of the law to be applied
in most of the questions which used to depend on domicile. Thus as
between themselves they have greatly simplified the determination of
those questions, but a similar elimination of domicile is impossible in
what concerns British subjects, because the British empire continues to
include a great variety of laws, as those of England, Scotland, the
province of Quebec, the Cape Colony, &c. Within the British dominions
domicile is the only available criterion of the legal character of a
British subject, and all British courts continue to apply the same
criterion to British subjects outside those dominions and to foreigners,
so that, for example, the age of majority of a British subject or of a
Frenchman domiciled in Germany would be referred by a British court to
German law. Indeed so deeply is the principle of domicile seated in
British law that only legislative action could allow a British court to
substitute a new principle. And even a French, Italian or German court,
applying political nationality as its new criterion to the legal
character of a British subject, could obtain no definite result unless
it supplemented that criterion by the old one, domicile, in order to
connect the person in question with one of the legal systems existing in
the British dominions.

Again, so long as the change of the criterion has not become universal,
a new question is introduced by its having been made in some countries
only. Denmark being one of those European states which still adhere to
the principle of domicile, we will take it as an example in order not to
complicate the illustration by such differences of internal law as exist
in the British dominions. Suppose that a Danish court has to decide on
the age of majority of a Danish subject domiciled in France, Italy or
Germany. Its rule refers the question to the law of the domicile, and
the law of the domicile refers it back to the law of the political
nationality. What is to be done? This and all other questions relating
to the application of the princ