ABSTRACT
One of the most striking features of the private international law of succession is the apparent continuity of basic principles in England and in much of the common law world. There are basic differences in approach between common law countries on the one hand and most civil law systems on the other, and even when a compromise has been negotiated its general acceptance has not so far been achieved. This chapter proposes to look at what are perceived as two of the principal points of difficulty and the attempts to deal with them by international convention. It considers the principal obstacles to greater uniformity in the field of succession stem from the two matters: the principle of scission; and the choice of connecting factor. The Convention would involve English law as well as other common law systems abandoning the application of the lex situs for succession to immovable property and hence the replacement of scission by unity of succession.
