Autonomy in International Contracts
This book examines a fundamental issue in private international law, namely the question of which country's law should be applied to determine what a contract means and to establish each party's contractual obligations. Generally speaking, if the parties to a contract state in the contract which country's law they wish to apply, that decision will be respected by the courts; this is the principle of autonomy of choice of law to which the book's title refers. Peter Nygh, an Australian judge and one of the world's leading authorities in the field, provides a detailed analysis of the principle which will enjoy international appeal. The book focuses on the legal systems of the United States, the Commonwealth jurisdictions and the civil law countries of western and central Europe, taking as a starting point the provisions of the several Hague Conventions on the Choice of Law in Sales and other contracts, the Rome Convention of 1980 on the Law Applicable to International Contracts and the Mexico Convention of 1994 on the same topic, as well as modern legislation on conflicts of law.