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In modern society, the role of marriage and its termination through divorce have become political issues.

Once a court accepts jurisdiction, it is for the lex fori to apply its own choice of law rules: both Ireland and the United Kingdom apply the lex domicilii; the other EU states apply the law of habitual residence.

Three public policies are relevant in the general conflict system: A distinction must be made between forms of divorce that are based in a court system administered under a system of law, and divorces that take place in quasi- or extrajudicial setting, i.e.

without any formal supervision from the local court system.

In both cases, once jurisdiction has been established, the lex fori will be applied to determine whether the local ground(s) of divorce have been satisfied and, if so, the marriage will be terminated with or without ancillary orders being made.

Since this is an issue affecting the status of the parties, the standard choice of law rules would be either: Although the law of the nationality may be reasonably easy to identify since it is often merely a matter of registration in the given country, a person may have, say, a Greek nationality but have had a permanent residence in New York State for twenty years without becoming a naturalised American.

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