Tindal CJ. It was broadly accepted by counsel for all parties that if the French limitation rule was a substantive rule (ie. the claim was negated by the effluxion of time), then because the promissory note was governed by French law there would be a good defence. However if the French rule was only procedural (ie. it barred the remedy but did not extinguish the right) then it would not apply, as the English court would always apply its own procedure to matters before it and foreign procedural rules were not to be applied. Judgment of Tindal CJ Although both counsel agreed upon the basic principle of law, the Chief Justice reviewed the position quite carefully. He considered the case of British Linen Company v Drummond (1830) 10 B&C 903, 109 ER 683 and the authorities cited therein. He also considered at length the treatise by the American jurist, Joseph Story in his Commentaries on the Conflict of Laws. He then agreed the basic principle that if a foreign rule was procedural it should not be applied in English proceedings. But if it were substantive, and that relevant foreign law was the proper law to determine the issue, then it should. He expressed the point in judicial language characteristic of the era: The distinction between that part of the law of the foreign country where a personal contract is made, which is adopted, and that which is not adopted by our English courts of law, is well known and established; namely, that so much of the law as affects the rights and merit of the contract, all that relates ad litis decisionem, is adopted from the foreign country; so much of the law as affects the remedy only, all that relates ad litis ordinationem, is taken from the lex fori of that country where the action is brought; and that in the interpretation of this rule, the time of limitation of the action falls within the latter division, and is governed by the law of the country where the action is brought, and not by the lex loci contractus... Having determined then, Tindal CJ then considered carefully the relevant provisions of French law (in the original French) as well as the commentaries of noted French legal scholars, including Pothier's Traité des Obligations. He decided that the French rule was a rule of procedure as it only barred the bringing of