and is a power retained by the sovereign, not with the courts. The reasoning of the court in Australia through the spycatcher case was that complying with friendly foreign government decisions placed the courts in difficult positions in the future to determine matters which derived from the sovereign. This was confirmed in the UK through The Barakat Galleries v Government of the Islamic Republic of Iran. The identification of foreign penal laws or foreign revenge law is relatively straight forward, a foreign penal law is a law which imposes a fine and is paid to the state. English law considers this lex fori. Payment to a private individual is unlikely to be considered penal, even if the payment is seen as a penalty or deterrent. By contrast, a revenue law is one which a party cannot opt out of, enforcement cannot be by action in the English courts. The English courts determine a foreign revenue law on the ground that a party may receive a hand back as evidence that the obligation to pay the state is not a foreign revenue law. The third category of 'other public laws' is traditionally one which relate to a claim in action in which only a state can claim, such as tort damages and costs of quashing a rebellion/revolution. Any claim which is founded on a right which is uniquely governmental will not be adjudicated. English rules will also limit choice of law where matters offend English public policy. It overrides foreign lex causae. An example may be of where a foreign government passes laws to strip certain parties of property wherein the property is not within the foreign government's jurisdiction. For example, Ruritania passes a law that all Ruritanian gold coins owned by a certain group are now owned by the state. If a Ruritanian citizen is living in London with possession of the coins in London, the English court will not recognise an action for adjudication by the Ruritanian government to recover the coins. This relates both to foreign law and to public policy because the foreign law is so repellent to English standards that even to know that it was made was unbearable. In the non-commercial context, this will often apply to matters of divorce and marriage as well. A foreign law which allows marriage of uncle and niece will not be contrary to English Public Policy, however, if the