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 The rights which are created in land are those which existed under the whole law of the situs and as would be enforced by those courts which normally would possess exclusive judicial jurisdiction (Griswold, Renvoi Revisited, 51 Harv. L. Rev. 1165, 1186; cf. Schreiber, The Doctrine of Renvoi in Anglo-American Law, 31 Harv. L. Rev. 523, 559). If another court is thrust into a position where it is obliged to adjudicate the same questions concerning title to that land, or a substitute therefor, it should be guided by the methods which would be employed in the country of situs. The purely fortuitous transfer of the problem to the courts of another State by virtue of a post-mortuary conversion of the land, effected for the purpose of administering the entire estate in the country of domicile, ought not to alter the character of the legal relations which existed with respect to the land at the date of death and which continued to exist until its sale. Consequently, a foreign court, in making a determination of ownership, must ascertain the body of local law to which the courts of the situs would refer if the matter were brought before them.

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