Case No. ZC20D00020

[1988] AC 92, the House of Lords held that a court considering such an application for a stay should adopt the same approach as that adopted at common law in cases of forum non conveniens. Accordingly, the court should not, as a general rule, be deterred from granting a stay merely because the petitioner in this country would be deprived of a legitimate personal or juridical advantage provided that the court was satisfied that substantial justice would be done in the appropriate forum overseas. In that case, it was impossible to conclude, having considered the matter objectively, that justice would not be done if the wife was compelled to pursue her remedy for financial provision in France, which was plainly the natural forum for the resolution of the matrimonial dispute.62.I have been referred to a number of authorities in which the English court has considered applications for discretionary stays where there have been marriage contracts or pre-marital agreements of one sort or another. In