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v. Innes (), Sinclair and Sutherland v. Frazer () and Kerr v. Alexander Earl of Home ().156 More generally, Huber’s overall reputation in the seventeenth century was immense. For example, he is cited with great approval by Sir George Mackenzie in his inaugural address in opening the library of the Faculty of Advocates.157 The main architect of early English conflicts law was Lord Mansfield, who was a Scot.158 Although he left Scotland when he was fourteen, never to return, he retained his Scottish connections. England was remarkably bereft of legal scholars in general until the nineteenth century. Moreover, conflict of laws was not really discussed in common-law courts until the time of Lords Hardwicke and Mansfield in the eighteenth century, primarily as a result of issues of jurisdiction. Unless a cause of action arose within a particular jurisdiction it was not actionable there. It is worthy of remark, that the first reference to Huber in the English reports is by Lord Mansfield ininRobinson v. Bland159. Yet, it is plausible to suggest that Huber was cited in the English courts before this. He had been cited in Scottish cases with approval on comity  156 Respectively, M. 4512, M. 4520, M. 4542, M. 4522. 157 Oratio Inauguralis in Aperienda Jurisconsultorum Bibliotheca (1689); see the edition of Edinburgh, 1989. P. 67, with nn. 29 and 32 by J.W. Cairns. 158 For the impact of Lord Mansfield on the development of English conflict of laws, see, e.g., Cheshire and North’sPrivate International Law, 11th edd., P.M. North and J.J. Fawcett (London, 1987), pp. 24 ff.; A.E. Anton, ‘The Introduction into English Practice of Continental Theories on the Conflict of Laws,’ 5 International and Comparative Law Quarterly (1956), pp. 534ff., at pp. 538ff.; C.P. Rodgers, ‘Continental Literature and the Development of the Common Law by the King’s Bench: c. 1750-1800,’ in Courts and the Development of Common Law, ed. V. Piergiovanni (Berlin, 1987), pp. 161ff., at pp. 182ff. 159 1 Bl. W. 234 at p. 257; 2 Burr. 1077. IV

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