No extra-territorial effect will be given by courts of foreign jurisdictions to a law dissolving attachments upon the institution of proceedings in insolvency, even as against citizens of the State where the law is in force. Rhawn v. Pearce, 110 111. 350; Kidder v. Tufts, 48 N. H. 121; Hibernia Nat. Bank v. Lacombe, 84 N. Y. 367. See also Paine v. Lester, 44 Conn. 196.

taken together, constitute the insolvent law of nations; and that each State will regard the peculiarities of its own law, but will respect, as far as possible, the law of other nations, and will regard the general principles in which all agree, as belonging to the system of law which is obligatory upon all; and among these general principles is that of a sequestration, for the general good of all the creditors, of all the property of the insolvent.

The courts of England, France, (u) and Holland, (v) certainly lean towards the latter view of this subject There it seems to be established, that a transfer in bankruptcy operates in the same way as a sale or other voluntary assignment for value by the insolvent, and effectually conveys all his property, wherever * it may be, in the same manner and with the same consequences as if he had sold it (w) There are obvious our courts have regarded the bankrupt laws of any State as of strictly municipal origin and application, and as wholly without force or influence abroad, (x) Hence it may be regarded as established here, by * the past adjudication on these cases, that any American creditor may, by process of law, retain any property of his debtor which he can get a legal hold upon, by transfer, attachment, or levy, against the claims of any for-eign assignee in bankruptcy, (y)1

(u) See the Appendix to Cooke's Bankrupt Law, p. 27 et seq where the case of Parish v Sevon is reported, as having been decided in the French court, which accords precisely with the English doctrine on the subject, cited by Chancellor Kent, in Holmes v. Remsen, 4 Johns. Ch. 484.

(v) The grounds of the decisions of the courts of France and Holland, are thus summed up by Story, J., in his Conflict of Laws, § 417 • l. That the law of the dom icil may rightfully divest the debtor and the administrator of his property, and place it under the administration of assignees or syndics. 2. That laws, whose effects are to regulate the capacity and incapacity of persons, their personal actions and their movables, everywhere belong to the category of personal statutes. 3. That it is a matter of universal jurisprudence, and especially of that of France and the Netherlands, that the debts, actually considered, of an inhabitant against a foreigner, are deemed a part of his movable property, and have their locality in the place of domicil of the creditor. At the same time, it is admitted that a purchaser from the bankrupt, in a foreign country, of property there locally situate, would be entitled to hold it against the assignees, if, at the time, he had no knowledge of any bankruptcy, or of any intent to defraud creditors. And see Henry on Foreign Law, pp. 127, 135, 153, 160, 248, 250; Merlin, Repertoire De Jur. Faillile et Banqueroute. (w) A leading case in England upon this subject is that of Sill v. Worswick, 1 H Bl. 665. The question considered by the court, without going into the details of the case, was simply whether an assignment in bankruptcy in England, carried with it money of the bankrupt in the island of St. Christopher, where the laws of England have no binding force as against a creditor there, who had attached the property, after the act of bankruptcy, but before assignment The authorities were examined at great length in the argument, and by the judge who gave the opinion of the court And Lord Loughborough said: "It is a clear proposition, not only of the law of England, but of every country in the world, where law has the semblance of science, that personal property has no locality. The meaning of that is, not that personal property has no visible locality, but that it is subject to that law which governs the person of the owner. With respect to the disposition of it, with respect to the transmission of it, either by succession or the act of the party, it follows the law of the person. The owner, in any country, may dispose of his personal property. If he dies, it is not the law of the country in which the property is, but the law of the country of which he was a subject, that will regulate the succession. . . . Personal property, then, being governed by the law which governs the person of the owner, the con-ition of a bankrupt by the law of this country is, that the law, upon the act of bankruptcy being; committed, vests his property, upon a just consideration, not as a forfeiture, not on a supposition of a crime committed, not as a penalty, and takes the administration of it by vesting it, in assignees, who apply that*property to the just purpose of the equal payment of his debts. If the bankrupt happens to have property which lies out of the jurisdiction of the law of England, if the country in which it lies proceeds according to the principles of well regulated and powerful reasons * why this view should be adopted universally. The same reason for desiring to make uniform the laws of our several States respecting bankruptcy, would lead to the same wish in respect to the commercial nations of the world. That every nation has a perfect right to regulate this matter by its own laws, so far as it concerns its own courts and its own citizens, no one doubts. The only question is, whether that amity of nations which is grounded upon the highest expediency, and the real advantage of each one, would not lead to this result In this country it has been held otherwise. And justice, there is no doubt but it will five effect to the title of the assignees The determinations of the courts of this country have been uniform to admit the title of foreign assignees In the two cases of Solomons v Ross, and Jollett v. Deponthieu, where the laws of Holland, having, in like manner as a commission of bankruptcy here, taken the administration of the property and vested it in persons who are called curators of desolate estates, the Court of Chancery held that they had immediately, on their appointment, a title to recover the debts due to the insolvent in this country, in preference to the diligence of the particular creditor, seek-ing to attach those debts. In those cases the Court of Chancery felt very strongly the principle which I have stated, that it has had a very universal observance among all nations The doctrine of the English cases seemed based on two leading principles. First, that the system of bankrupt law ought not to be considered local, but universal, and that the whole system of bankruptcy should be held to be part of the law of nations, and, as such, the acts of one nation thereunder should be equally respected in all. The other is, that the effect of the bankruptcy and assignment is to sequestrate all the bankrupt's property at once, and to transfer all his interest to his assignees, as in the case of a voluntary transfer or grant; that is to say, they regard the act as his own, though done under compulsion of the law." The leading case, also of Royal Bank of Scotland, etc. u. Cuthbert (Stem's case), 1 Rose's Cases, 462; Selkrig v. Davies, 2 Rose, 291; Quelin v. Moisson, 1 Knapp, 265; Selkrig v. Davies, again reported 2 Dow, 230; Ex parte D'Obree, 8 Ves. 82; Pipon v. Pipon, Ambler, 25; In re Wilson, 1 H. Bl. 691; Solomons v. Ross, id. 131, note; Jollett v. Deponthieu, id. 132, note; Neil v. Cottingham, id.; Hunter v. Potts, 4 T. R. 182; Ex parte Blakes, 1 Cox, 398; Smith v. Buchanan, 1 East, 6; Potter v. Brown. 5 id. 124-131: