The judges seem to find some intrinsic connection with the foreign law of the domicile and accordingly seem reluctant to achieve results incompatible with the application of that law. If than, the characterization of the problems in a case with many foreign elements or the approach of choice-of-law rules would achieve results different from those of the lex causae, the courts seem reluctant to go down that path. This may be attributed in part to a desire to promote a certain degree of international consistency as regard the status of the parties or a desire to avoid being chosen as a favourable forum, but whatever the reasons, the tendency to apply the foreign rules is evident.