Module 15 - Choice of law in contract
Topics
- Rome 1 Regulation
- Temporal application
- Interpretation
- Application – Subject matter
- Exclusions
- Applicable law where exclusions apply
- Application – Non-contracting states
- Application within the United Kingdom
- Renvoi
- Party autonomy
- Express choice
- What is meant by “law” in this context?
- Implied choice (“demonstrated with reasonable certainty”)
- Dépeçage (“whole or a part only”)
- Change of governing law
- Law governing consent
- Mandatory rules of another law
- Anti-avoidance – Mandatory rules of sole country connected with situation
- Anti-avoidance – Mandatory rules of forum
- Anti-avoidance – Public policy of forum
- Anti-avoidance – Mandatory rules of European law
- Anti-avoidance – Mandatory rules of place of performance
- Governing law in the absence of choice
- Comparison between Art 4 of Regulation and Convention
- Carriage of Goods
- Carriage of Passengers
- Assignment of contractual rights
- Scope of Applicable Law
- Material Validity
- Formal Validity
