What is true for European-made law, when it operates in an English court, is equally true of the “common law”—used in this context as convenient shorthand for common law plus Parliamentary legislation—when it applies in an English court, which it still does, albeit in an increasingly residuary way. The common law is just as autonomous, and independent of European law, as European law is of it—not just in the meaning of terms, but in operation and application; indeed, as the courts deal more and more with law of European origin, it is the autonomy of the common law which needs to be observed and protected, rather than the other way round. This separateness, of each system from the other, needs to be taken to heart. It is not that the two systems of private international law were designed to be separate; rather, they were designed to be self-contained and self-sufficient, and separateness is the necessary result: one courtroom, two systems, as one might say.2 In terms of jurisdiction, each scheme determines for itself whether a court has or does not have judicial power to adjudicate, or to decline to adjudicate, a matter brought