So, once a conflicts lawyer has given an answer to the question of choice of law, and has explained which system’s rules will provide the legal answer, what happens next? What do we know about the role actually, as opposed to presumably, played by foreign law in proceedings in the English courts? The answer has been very clear for a very long time: foreign law is pleaded, deposed to and found as a fact which the parties to litigation may rely on or not, as they alone choose; and in the absence of such pleading, proof and finding, a case will be resolved by the application to it of only English law. This is axiomatic (and is a Rule in Dicey & Morris, it being hard to say which is the higher authority), and Mr Fentiman reminds us it is so again and again and again. It is true enough that there are wrinkles in the clarity of this picture. This is a quaint, if inoffensively meaningless, proposition that foreign law is presumed to be the same as English law unless the contrary is established: it may be nonsensical, but it does not seem to have done any harm, for it brings about the same result as the rational explanation. Then there are statutes which occasionally appear to demand that a foreign law be applied, instructing a judge that the law of a particular country “shall” be applied, is “mandatory”, and so on. But for a statute to tell a judge which law