Supreme Court of New Hampshire June 1, 1909 (Kimball v. Kimball)

*292

Peaslee, J.

As between the

lex loci

and the

lex fori,

the former governs both in torts and contracts, in respect to the legal effect and incidents of the acts. Whatever would be a defence to this action if brought in the state where the transactions took place is a defence here.

Beacham

v.

Portsmouth

Bridge, 68 N. H. 382;

MacDonald

v.

Railway,

71 N. H. 448, 450.