page 90 note * No more taken into account by the Court of Appeal, the Convention being denounced with effect as from June 1, 1969.

page 91 note * A common argument is that the marriage relationship is lived out in a Netherlands “legal atmosphere”, having regard to the place of celebration of the marriage and/or of the birth of the children, (former) (common) nationality or domicile of the parties, employment, etc. Twice this reasoning has led to application of foreign law of the last common domicile. The “legal atmosphere” criterion has been recommended by Sauveplanne, J. G. in Internationaal privaatrechtelijke vraagstukken met betrekking tot de echtscheiding, Report submitted to the Annual Meeting of the Ned. Juristenvereniging, 1971Google Scholar; it was accepted by a large majority during discussion of the Reports, even for the situation in which both spouses have the same nationality.