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  2. Convention on the Law Applicable to Contractual Obligations 1980

    en.wikipedia.org/wiki/Convention_on_the_Law...

    For these purposes, it is presumed that the contract is most closely connected with the lex loci solutionis, i.e. the law of the place where the contract is to be performed, or the law of the habitual residence of the person who is to perform, or, in the case of a body corporate or unincorporate, where its central administration is located.

  3. Lex loci - Wikipedia

    en.wikipedia.org/wiki/Lex_loci

    Lex loci celebrationis is a Latin term for a legal principle in English common law, roughly translated as "the law of the land (lex loci) where it was celebrated". It refers to the validity of the union, independent of the laws of marriage of the countries involved: where the two individuals have legal nationality or citizenship, or where they ...

  4. Lex loci contractus - Wikipedia

    en.wikipedia.org/wiki/Lex_loci_contractus

    In contract law, the lex loci contractus is the Law Latin term meaning "law of the place where the contract is made". [1] [2] It refers (in the context of conflict of laws) to resolving contractual disputes among parties of differing jurisdictions by using the law of the jurisdiction in which the contract was created.

  5. Conflict of tort laws - Wikipedia

    en.wikipedia.org/wiki/Conflict_of_tort_laws

    In exceptional circumstances, the lex loci delicti rule is displaced in favour of another law, if the "factors relating to the parties" or "any of the events which constitute the tort" show that this other law will be substantially more appropriate. Suppose that an English employer sends an employee on a business-related journey to Arcadia.

  6. Conflict of laws in the United States - Wikipedia

    en.wikipedia.org/wiki/Conflict_of_laws_in_the...

    Courts may look for a provision in the law of the choice of law state that permits the court to use the lex fori, i.e. law of the forum state. For example, suppose State X has a rule that says that if property located in State X is conveyed by a contract entered into in any other state, then the law of that other state will govern the validity ...

  7. Choice of law - Wikipedia

    en.wikipedia.org/wiki/Choice_of_law

    If so, the court may be able characterize the claim as a breach of the contract, instead of a tort, and apply the law of the State A either because it was the place where the contract was made (the lex loci contractus) or, if it were the place where the wage or salary was to be paid, where the contract was intended to be performed (the lex loci ...

  8. Procedure in conflict of laws - Wikipedia

    en.wikipedia.org/wiki/Procedure_in_conflict_of_laws

    The lex fori determines whether a foreign judgment can be recognised and, if so, how it will be enforced, e.g. what property belonging to the defendant may be taken to satisfy the judgment (see enforcement of foreign judgments). But in the Law of Contract, this is subject to Article 10 of the Rome Convention 1980 which provides that the ...

  9. Proper law - Wikipedia

    en.wikipedia.org/wiki/Proper_law

    Similarly, picking the lex loci solutionis, i.e. the law of the place where the contract is to be performed, may prove to be equally irrelevant, assuming that there is only one place where performance is to occur: in the example, there is manufacture in Greece, delivery to Belgium, loading in Belgium, carriage on the high seas, and unloading in ...