What is the test for using lex rei sitae in the context of an application where the language is substantially similar?
Saskatchewan, Canada
The following excerpt is from Burnfiel v. Burnfiel, 1926 CanLII 113 (SK CA):
The decision in Ross v. Ross, supra, as will have been seen, confines the broad rule to where the laws relating to adoption of the domicile of adoption and the lex rei sitae relating to the same subject are substantially similar.
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