Winkworth v Christie Manson and Woods Ltd [1980] 1 Ch 496 was a judicial decision of English High Court relating to the proper law to determine whether title passes when stolen goods are sold to another person in a foreign country.

The plaintiff neither knew of or nor consented to the removal of the goods to Italy or any subsequent dealings with or movements of them up to the time when the said undertakings were given.

The case was heard by way of determination of a preliminary issue, and the certified point for determination was: Whether upon the basis of the agreed facts set forth in the schedule ... English domestic law or Italian domestic law is to be applied to the issue whether the plaintiff or the [second] defendant ... has title to the goods with which this action and the said counterclaim are concerned and to the proceeds of sale of those goods ...

He also referred to the rule being upheld in Re Anziani [1930] 1 Ch 407 and quoted Devlin J in Bank Voor Handel en Scheepvaart NV v Slatford [1953] 1 QB 248 at 257 stating: "There is little doubt that it is the lex situs which as a general rule governs the transfer of movables when effected contractually."

Accordingly, the plaintiff was thrown back on trying to show that Italian law should be disapplied as a matter of public policy.