What is the test for conflicts of law relating to adoption and domiciliary law?

Alberta, Canada

The following excerpt is from H.K.L. (Re), 1988 CanLII 3559 (AB QB):

Paquette v. Galipeau, 1981 CanLII 160 (SCC), [1981] 1 S.C.R. 29, 22 R.F.L. (2d) 192, 37 N.R. 421 [Que.], considered the matter of conflicts of law relating to adoption, and was of the view that there must be a cumulative application of all the substantive conditions of both laws, i.e., that the question of whether a child was one who could be adopted should be referred not only to the domiciliary law of the applicants, but also that of the child. Conclusion

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