This book offers a contractual framework for the regulation of party autonomy in choice of law. The party autonomy rule is the cornerstone of any modern system of choice of law; embodying as it does the freedom enjoyed by parties to a cross-border legal relationship to agree on the law applicable to it. However, as this study shows, the rule has a major shortcoming due to its failure to give due regard to the contractual function of the choice of law agreement. By looking at the existing law from several jurisdictions (including both common and civil law jurisdictions), and international...
This book offers a contractual framework for the regulation of party autonomy in choice of law. The party autonomy rule is the cornerstone of any mode...