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UPA Perpustakaan Universitas Jember

A Comparative Study of Australia and Slovenia’sPrivate International Laws and the Applicationof Citizenship and Residence

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This article shows that the transnational engagement of citizens betweenAustralia and Slovenia, and other countries in not new. Slovenia and Australia havea long standing relationship that dates back to the late nineteenth century. Thisarticle compares the private international laws (PIL) of Australia and Slovenia, andthe application of citizenship and residence. Transnational engagements in privateactivities such as marriage, founding a family and purchasing property in anothercountry other than the citizen’s country of origin has been occurring for decades.Australia and Slovenia have taken a very different approach to the administrationand regulation of private international law. The article attempts to address thedifferences taken by both states in developing their respective regulatory frame-works to regulate PIL matters. A key feature of Australia’s common law system isthe responsibility of the judiciary to determine the choice of law. Australia, whencompared to Slovenia has limited legislation specific to PIL. Slovenia has a singleprivate international law act. Finally, this article will also highlight the differencebetween the common law and civil law principles of domicile and resid

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