Page "Conflict of laws" Paragraph 38
from
Wikipedia
Generally, when the court is to apply a foreign law, it must be proved by foreign law experts.
It cannot merely be pleaded, as the court has no expertise in the laws of foreign countries nor in how they might be applied in a foreign court.
Such foreign law may be considered no more than evidence, rather than law because of the issue of sovereignty.
If the local court is actually giving extraterritorial effect to a foreign law, it is less than sovereign and so acting in a way that is potentially unconstitutional.
The theoretical responses to this issue are:
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