not generally be regarded in other countries where the like disqualifications do not exist; Hence penal disabiUties and disqualifications resulting from slavery, heresy, excommunication, and the like, are strictly territorial.^ But transactions concerning real estate are, as we have already stated, governed solely by the lex rei siice.^ And the principles of the common and civil law are alike on this point, both maintaining the sovereignty over the soil, and that the laws of the ' 1 Burge. Com. on Col. & For. Law, 132. ^ Hertii , Opera Be Collis Leg., 124; 1 Burge. Com. on Col. <& For. Law, 734; Ifcn. on For. Law, 30; 2 Hagg. Adm. R., 94; Boulknois Obs., 52; 1 Voet. ad Pand., p. 40.
" 2 Dwarris on Stat., 648 ; Warrender v. Warrender, 9 Bligh E., 127 ; 2 Burge. Com. on Col. & For. Law, pt. 2, o. 4.
place where such property is situated, shall exclu- sively govern in respect to the rights of the parties, and the manner and ceremonies attending the trans- fer thereof, therefore the title to real estate can only be acquired, passed or lost, and the abilities, rights and duties of the parties