The law of the place where the contract was made. Lex Domicilii: The law of the person's permanent home.
A court judgment is often useless if it cannot be enforced. If a claimant wins a $1 million judgment in London against a company whose only assets are in Tokyo, they must take that English judgment to a Japanese court. The Conflict of Laws
Modern approaches have shifted toward the doctrine, which seeks the legal system with the most "significant relationship" to the transaction and the parties. 3. Recognition and Enforcement: Is the win valid elsewhere? The law of the place where the contract was made
Even if a court in New York agrees to hear a case, it doesn’t necessarily mean they will use New York law. If two French citizens sign a contract in Paris and later sue each other in New York, the judge may be required to apply French law to the dispute. To decide this, courts use "connecting factors": If a claimant wins a $1 million judgment
Under the principle of , nations generally respect the judicial acts of others, provided the original court had proper jurisdiction and the proceedings were fair (not contrary to "public policy"). Without this mutual recognition, international trade would be paralyzed by legal uncertainty. The Core Tension: Sovereignty vs. Justice
The law of the place where the wrong (tort) was committed.
It fundamentally addresses three questions: , Choice of Law , and Recognition of Judgments . 1. Jurisdiction: Where should the case be heard?