movable effects also, in whatever place they may be situated, according to the maxim that movables follow the person. Mohilia sequuntur personam ; and any disposition of them will generally be considered valid or not, ac- cording to the law of the domicil. This rule, how- ever, as indeed all the rules relative to personal abilities and disabilities, are subject to infinite ex- ceptions, which it would be foreign to the subject of this treatise to notice here, and they -nill therefore only be alluded to as occasion seems to require. But the rule is different in regard to real or immovable property. The law of the place where real propert}is situated, regulates the disposition of it ; and when the law of the domicil and that of the situs are in con- flict with each other, if the question is respecting person, the law of the domicil ought to prevail ; but if it is respecting the property, the law of the place where it is situated is to be followed.^ Thus, where the laws of the domicil declare that a minor or a married woman, or others, are incom- petent to contract in the place of his or her domicil, they will generally be deemed to be incompetent, everywhere ; consequently, if a citizen of France, in ^1 Biirg. Comment, on Col. and For. Law, p. 113; 1 Boulh'nois, p. 103.
^ Merlin^ Repertorie Universal et JRaisonne de Jurisjprudence. See, 10, art. 2.
REAL LAWS. 103 his own country, who is under the age of twenty-five years, should order or purchase goods in this country, he will not be bound by his contract, for he is, by the laws of his domicil, deemed a minor, and there- fore incapable of making such a contract. And this rule is good where it relates to the disposition of personal or movable property. But if a Frenchman who is a minor by the lex loci domicilii, makes a con- tract in a country where, by the law of that place, he had attained the age which constitutes majority, and where accordingly he is competent to contract, the lex loci contractus in such a case will govern, and he may make a valid contract.-^ Mere personal disqualifications, however, created by the customary or positive law of one country, will