Reviewed case brief
Carl Zeiss Stiftung v. Rayner and Keeler Ltd
[1967] 1 AC 853
## Summary
- Court
- House of Lords
- Year
- 1967
- Subjects
- Public International Law
- Reviewed
- 2026-06-28
Rule established
Courts may recognise the acts of an unrecognised government as valid if that government acts as a subordinate or agent of a recognised sovereign state. The "agency theory" allows circumventing non-recognition where practical necessity demands.
Facts
Issues
Held
Ratio decidendi
How to use it in an exam
Editorial source
[1967] 1 AC 853
Educational summary only. Read the reported judgment or an authorised law report before relying on the case professionally.