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1) A number of other states, including Australia, Canada, South Africa, and the United Kingdom, have codified the restrictive theory of sovereign immunity. However, the

1) A number of other states, including Australia, Canada, South Africa, and the United Kingdom, have codified the restrictive theory of sovereign immunity. However, the shift from the absolute to the restrictive theory of immunity is hardly universal; China, India, Indonesia, and Russia, among others, still adhere to the absolute theory of immunity. What factors might prompt states to adopt the restrictive theory?

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