Article Art. 4(1)1 of the German Private International choses to selectively apply renvoi as for those situations where the law of another country could support the issue raised as renvoi for its meaningful cause. Where the foreign law applied, then the German standpoint on renvoi presents that the foreign nations conflict law applies. In the case of an understanding of renvoi in Chinese Private International Law, it is stated in Article 9 that when a subject is renvoi’d then the foreign law could be applied to the civil relation and issue would not include the conflict rules of the country where renvoi is admitted. Before the year 2010 the Chinese legislation was silent on what was to be the renvoi and judicial interpretation on the renvoi in China. A choice to even exclude it completely was suggested by a judicial interpretation made in Paragraph 2 of Article 178 of the General Principle of Civil Law of the People’s Republic of China. Although such an exclusion could in fact have simplified the law in renvoi, this could have led to issue as renvoi of the past years have shown some situation of rejection which ends up convenient for promoting justice and in others would have to be rejected.
However, Chinese law scholars have been advocating for an inclusion of renvoi at least in some fields on the context that it would support the cases of lex fori where international decisional harmony would be ensured. Where a stance towards a near complete rejection of Renvoi as article 9 stipulates is allowed then it leads to a situation where a partial permit would complicate the judicial tasks of judges more. It should either have been rejected or have been permitted completely with care taken to ensure that the foreign country law and conflict rules does not change the meaning for which the renvoi is raised. Now since such a standpoint in renvoi has not been taken it so happens that there is a possibility for application of forum law with not much consideration for other country’s conflict rules as they would not be applicable anyways according to Article 9. Additional concerns are raised at this point as to whether the foreign law’s procedural law needs to be considered. A very literal interpretation of Article 9 leads to an affirmative answer here. Procedural issues are usually governance by the lex fori and hence are to be considered as being a well-established and a universally accepted principle. They can neither be considered as a legislative will of a particular country.