Absence of an Ante-Nuptial Contract Case Study

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Facts
A husband and wife were married in Czechoslovakia, which was the domicile of the wife. The husband was domiciled in Germany as it was his domicile of origin.
The wife and husband had intended and agreed to leave Germany and establish a permanent home in Johannesburg at the time of the marriage as the husband had been promised a permanent job. After moving to Johannesburg, the husband was transferred to Durban, in which the couple had the intention of settling there permanently and the husband was naturalised as a British subject.
In 1984 the husband died. There was no ante-nuptial agreement, which meant that the couple was married out of community of property as they were married under German law.
Issue
Which law is applied to determine the matrimonial propriety rights of spouse in absence of an ante-nuptial agreement?
Ratio
In the absence of an ante-nuptial contract, the matrimonial regime of spouses not domiciled in the same country is subsequently governed by the law of the husbands domicile at the time of the marriage and not by the domicile intended to be acquired imm...

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