the Introductory Law of the German Civil Code (1900) adopts it. But if both sets of laws operate with either no renvoi system or single renvoi systems, forum shopping will be a potential problem. Hence, there is another system called Double Renvoi or the Foreign Courts Doctrine which will also ensure parity of result so long as no other relevant law is using it. In this scenario, the forum court considers that it is sitting as the foreign court and will decide the matter as the foreign court would. In this system, there can never be more than two remissions, e.g. English forum refers to French law (a single renvoi system) so English law is applied (1st remission) and France accepts the remission (2nd and final). At present, only English law uses this approach. Application of renvoi Because the doctrine is considered difficult and its results are sometimes unpredictable, its application has generally been limited to: the validity of wills and intestate succession (the validity of transfers of real property); and retrospective legitimation by the marriage of the natural parents (validity of divorce decrees). However, there are indications in some states that it might also apply to two issues in family law, namely the capacity to marry and the formal validity of marriage. EU In the European Union, application of renvoi is expressly excluded in contract cases under article 20 of the Rome I Regulation (regulation (EC) 593/2008l formerly in Article 15 EC Convention on the Law Applicable to Contractual Obligations, Rome 1980). It has also been rejected for contracts by most Commonwealth countries. Most states also exclude it in tort cases e.g. in the UK section 9(5) of the Private International Law (Miscellaneous Provisions) Act 1995. Since 11 January 2009, Regulation (EC) 864/2007 (the Rome II Regulation) on the law applicable to non-contractual obligations has been in force, controlling in a uniform way the rules throughout the European Union. Article 24 of this regulation provides: "The application of the law of any country specified by this Regulation means the application of the rules of law in force in that country other than its rules of private international law." hence excluding the possibility of renvoi throughout the EU in tort cases. Australia In Australia, the doctrine of renvoi was revived by the decision of the High Court in Neilson v Overseas Projects Corporation of Victoria Ltd [2005] HCA 54 (29