Is renvoi accepted in south African private international law?

Answer 1

In South African private international law, the doctrine of renvoi is generally not accepted. South Africa primarily follows the principle of direct application of foreign law without considering the foreign jurisdiction's choice of law rules. However, there are some instances where courts may take limited account of renvoi, particularly if it aligns with the interests of justice or the specific circumstances of a case. Overall, the approach tends to favor simplicity and predictability in legal outcomes.