ABSTRACT
The term 'succession' is used in a wide sense to cover all questions relating to the transfer of property on death. The principle of universal succession means that the entire estate of a deceased person passes automatically to his or her heir or heirs. In matters of succession, English law adopts situs as the connecting factor in relation to immovable property, but regards the succession to movable property as a matter for the personal law of the deceased. The 'adhesiveness' of the domicile of origin, especially in relation to matters of succession, is illustrated by Ramsay v. Liverpool Royal Infirmary. The classification of property is obviously important when the choice of law depends upon it. In relation to the applicable law, the Convention would establish unity of succession and seeks to achieve a compromise between countries that use domicile as a connecting factor and those that prefer nationality by abandoning domicile.
