But it may be difficult to determine where a person has a habitual residence if constantly on the move and has no real or continuing connection with any of the countries through which passed. This could be resolved by reference to the individual's intention, but although the test of intention is well-defined in the case law for the purposes of domicile, there is no consensus of the strength of intention that would have to be shown to establish "habit". Similarly, there is no consensus on the length of time a person should have a home for it to become habitual.