That is, it must be non-justifiable at the lex loci actus.

One might say that any rights that C might have are vested by the will that was made in Arcadia (i.e. the lex loci actus).

The incidental question was the validity of the divorce which was to be determined either by their lex domicilii at the relevant time or by Italian law as the lex loci actus.

Thus, if the get is effective under the lex loci actus and recognised under the laws relevant to determine status and capacity, it will be recognised so long as the best interests of the children are protected in any orders or agreements made by the parties.

While typically they both point to the same location, in the case of product liability, for example, the lex loci actus would be the place of manufacturing, while the lex loci delicti commissi would be the place of injury.

As a form of divorce, the rule might be that the lex loci actus (the law of the place where the transaction took place) should be applied and recognised universally so that the parties would avoid a limping marriage (i.e. that whether they are considered married will change depending on which states they visit or reside in).