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In all lawsuits involving conflict of laws, questions of procedure as opposed to substance are always determined by the lex fori, i.e. the law of the state in which the case is being litigated.

What issues are procedural?

This is a part of the process called characterisation. Issues identified as procedural include the following:

if the effect of granting the relief sought would offend against the public policy of the forum court;
if the effect of the relief would be so different from that available under the lex causae that it makes the right sought to be enforced a different right. For example, in English law, the court was asked in Phrantzes v Argenti [1960] 2 QB 19 to enforce a Greek marriage dowry agreement. Although the forum had no public policy objections and agreed that such agreements were enforceable, relief was denied because there were no local rules to calculate the amount to be paid. A different result would have been achieved if the agreement had stipulated a liquidated sum to be paid. Thus, in Shahnaz v Rizwan [1965] 1 QB 390, a deferred mahr (dowry) was enforced as part of an ante-nuptial agreement made in India in consideration of marriage at a time when ante-nuptial agreements were not generally enforceable under English law. The judge accepted the difference between maintenance and a dowry, and enforced payment as a right ex contractu rather than as a matrimonial right. Hence, a remedy was granted to enforce a right in personam, enforceable by the wife or widow against the husband or his heirs. The same result is achieved in the United States, see Aziz v. Aziz [1985] where a New York court enforced a deferred mahr of $5,000 because the terms of the contract complied with New York's General Obligations Law. The court rejected the husband's claim that it was a matrimonial action.