ABSTRACT
When an English court, applying its own conflict rules, has arrived at a foreign law and found it potentially applicable and not objectionable on policy grounds, the task of classification is not necessarily complete. Only rules of foreign law which are substantive2 will be taken into account; those which are procedural will be disregarded, as it is well established that the lex fori exclusively governs procedure.3 It is obvious that too broad a view of procedure, easier to take in the common law tradition4 than in others, perhaps, could subvert the whole conflicts enterprise by exaggerating the role of the forum and the English courts need to be wary of this.
