Under the traditional rule enunciated by Willes J. in Phillips v.
Eyre both the lex fori and lex loci delicti are relevant, to some extent, in actions upon foreign torts. The requirements of the rule, that the wrong be actionable if committed in the jurisdiction of the forum and not justifiable by the law of the place, have been subjected to considerable judicial and extrajudicial scrutiny. In relation to the latter element, the recent and already famous House of Lords decision in Chaplin v. Boys establishes that it is not necessary to show actionability under the lex loci delicti for each and every substantive matter. In the opinion of Lord Pearson and Lord Donovan something less than complete civil liability sufficed to render an act not justifiable where donc, while Lord Wilberforce and Lord Hodson appeared to require compliance with the lex loci delicti in all respects, but were prepared to create an exception for appropriate cases.