As criteria of domicile "may be mentioned the residence of a wife ud family, the purchase or ownership of land or a grave, prospects of succession to an estate, change of religion, education of ebiidren, ma riage to a native of the new country and the establishment of a permanent business there; but all are to be taken us subject to the inherent dimeulty of proving a change of domicile, especially of a domicile of origin, Westlake (Private Intérna~ tional Law, 7th Ed. by Bentivich) denies the necessity of an intention quatenus in ilia ex were patria as Proseribed in Moorhouse v. Lord (1803, 10 H. of L. 272) and considers the Present result of the English cases to be that the animus required for acquiring a domicile of choice "must be an intention to reside in the fullest and most permanent and in that sense to acquire a new domicile; but it need not be an intention to' subject himself to another system of law or to identity himself with the social ideas and habits of another country. If therefore it be described as an intention quatenus in ilia exuere patria, that can only be in the most external sense from which all the moral considerations that go to make up a patria are excluded." He proceeds: "The Intention necessary for. acquiring a domicile of choice excludes all contemplation of any event on the occurrence of which the residence would cease, The old English doctrine was that all desire or intention of return to the old country was not excluded, if only the event on wien the return depended was highly uncertain and regarded as remote. Thus the domicile might be changed by. residence abroad....as a merchant with the intention of remaining till a fortune should be made and then returning. But in later cases the tendency has been to treat an ex-
Text read from the printed page and cleaned; old type leaves the occasional error.