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A DC circuit, of course, does not need to be grounded. It just needs a path from the negative to the positive (the actual flow of electrons). One can often simplify the wiring by using a common "ground" bus which might include a car's chassis for example. If the negative terminal is grounded, then everything that is not "ground" would be positive. Likewise, if the positive terminal is grounded, then everything that is not "ground" is negative. Since you are looking at return paths... you could potentially have 2 batteries, one that is negative grounded and one that is positive grounded. Consider two 12 volt batteries: +12V(a) -- (-12)V(b) -- GROUND -- (+12V)(c) -- (-12V)(d) If you connect (d) to either (b),(c), or Ground, one would have a 12V difference with (d) being negative. If you connect (a) to either (b), (c), or Ground, then one would have a 12V difference with (a) being positive. If you connect (a) to (d) then one would have a 24V difference with (a) still positive and (d) still being negative. One note... When Steel is given a negative potential (charge), it corrodes less than when it is given a positive potential (charge). This is the reason why negative ground is almost universally used on automobiles.

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