The vital consideration in choice of lawis drawing the demarcation line between movable and immovable
property (Tan, Y.L., 1993). Miller, G. (2000) divided the rule of a choice of law into two parts, firstly, the legal
category that involve the determination of the question or issues raised by a particular case that arelex fori which
refers to the law of forum or lex causae referring to the law chosen by the forum court from among the relevant
systems to arrive at its judgment of an international or inter-jurisdictional case. Secondly, the factors connecting
the particular issue with a particular legal system namely, lex situsreferring to the law of the place in which the
property is situated and lex domicilii which refers to the law of domicile.