The persons who are to take under a will are decided by different rules according as the property is movable or immovable, the former being governed by the law of the domicile, the latter by the "lex loci rei sitae". It was held, however, in 1881 by the court of appeal in England that, under the will of an Englishman domiciled in Holland, leaving personal property to children, children legitimated "per subsequens matrimonium" could take, as they were legitimate by the law of Holland, though not by the law of England (re Goodman's Trusts, 17 Ch. D. 266). This principle was carried further in re Grey's Trusts (1892), 3 Ch. 88, where it was held that a legitimated child was entitled to share in a devise of English realty. But it is to be noted that a person born out of lawful wedlock, though legitimated, could not succeed as heir to real estate in England ("Birtwhistle v. Vardill", 2 Cl. and F. 895). A will duly executed abroad is generally required to be clothed with the authority of a court of the country where any property affected by the will is situate.