states, relying on one personal law rather than another may be arbitrary. To cope with that difficulty, Currie advocated that the lex fori should be applied whenever his method produced what he called a "true conflict".Critics have alleged that Currie's approach is nothing more than a complex pretext to avoid applying foreign law if there are two or more personal laws. Modern approach Since characterisation and the choice of law rules were operating inflexibly, the solution has been to allow the growth of judicial discretion within both parts of the system. Hence, most legal systems have opted for what English law calls the proper law approach: the identification and application of the law that has the closest connection with the cause(s) of action. It is accepted that the words have the same apparent spirit as the older approach, which requires some caution in their evaluation. In theory, flexibility will preserve an international outlook and multilateral approach by the courts and in most places, the results are encouraging. In the US, however, the test now adopted is termed the most significant contacts test or, in a slightly modified form defined in the Second Conflicts Restatement, the most significant relationship test. However, because different courts have interpreted these impressionistic phrases in different ways, there has been little judicial consistency. References Currie, Brainerd. (1963). Selected Essays on the conflict of laws p. 180. Lorenzen, Ernest G. (1947). Selected Articles on the conflict of laws. pp. 13–14. Savigny, Friedrich Karl Von. (1849). ''System des heutigen römischen Rechts". Vol. 3, pp. 121–26. Conflict of laws