Although there are only a few cases that have considered s. 2 of the Act specifically, there are several decisions from various courts which address the concept of submitting or attorning to a foreign court’s jurisdiction. The question is still relevant in jurisdictions that have adopted the real and substantial connection test because that test does not displace the common law, but simply enlarges the circumstances in which a foreign court has jurisdiction: Beals v. Saldanha, 2003 SCC 72,  3 S.C.R. 416, at para. 34.
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