Juliet Taylor, 2006
Against the background of an overview of retention of title regimes in Australia and New Zealand, the author explores conflict of laws issues in relation to trans-Tasman supply of goods. The article focuses on specific problems in this regard as a result of the divergence of the Australian and New Zealand regimes, as well as inadequately drafted conflict of laws provisions in the New Zealand Personal Property Securities Act 1999. The author emphasises the importance, also for Australian suppliers of goods to New Zealand buyers, of registering retention of title arrangements on the (New Zealand) Personal Properties Securities Register.
DW Rowe, 1980
In a discussion of the decision in Winkworth v Christie, Manson & Woods Ltd  1All ER 1121, the author questions the commitment of Anglo-Common law to the lex situs as the primary legal system governing transfer of movables and its effect on proprietary rights. In view of the different results that this may produce in relation to stolen goods, depending on whether the lex situs adheres to the nemo dat quod non habet principle or not, it is suggested that a distinction could be drawn, for instance, between consensual transactions (where the original owner is party to the transfer) and claims to over-reaching interests (where the original owner is not involved).