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Scholars and jurists agree that the concept is of a Scottish origin.<ref>http://www.mssc.state.ms.us/decisions/Publishedopinions/96-01284.HTM</ref><ref>{{cite web |url=http://www.judicium.it/news/pistis01.html#_edn1 |title=Forum non conveniens |website=www.judicium.it |url-status=dead |archive-url=https://web.archive.org/web/20021119182213/http://www.judicium.it/news/pistis01.html |archive-date=2002-11-19}} </ref><ref>http://works.bepress.com/context/graydon_staring/article/1008/type/native/viewcontent/</ref><ref>{{Cite web|url=http://supreme.justia.com/us/454/235/case.html|title = Piper Aircraft Co. V. Reyno, 454 U.S. 235 (1981)}}</ref> Some writers see the doctrine of FNC as having developed from an earlier doctrine of ''forum non competens'' ("non-competent forum"). Many early Scottish cases invoking FNC were under [[admiralty law]]. FNC thus may ultimately have a [[civilian law|civil law]] origin, as has been asserted by several writers, since admiralty law is based in civil law concepts.{{Citation needed|date=March 2022}}
In [[Scotland]], the concept is first recorded in ''MacMaster v. MacMaster'' (1833) 11 S 685).
===United Kingdom===
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