Codifying Choice of Law Around the World: An International Comparative Analysis

Codifying Choice of Law Around the World chronicles, documents, and celebrates the extraordinary, massive codification of Private International Law (PrIL), or Conflict of Laws that has taken place in the last 50 years, from 1962-2012. During this period, the world has witnessed the adoption of nearly 200 PrIL codifications, EU Regulations, and international conventions--more than in all preceding years since the inception of PrIL. This book provides ahorizontal comparison and discussion of these codifications and conventions, first by comparing the way they resolve tort and contract conflicts, and then by comparing the answers of these codifications to the fundamental philosophical and methodological dilemmas of PrIL. In the process, this book re-examines anddispels certain widely held assumptions about choice of law, and the art and science of codification in general.