TACIT CHOICE OF LAW IN INTERNATIONAL COMMERCIAL CONTRACTS: PROGRESS OR STAGNATION IN THE COMMON- LAW JURISDICTIONS?

The English common-law rules of private international law have, to a large extent, been replaced by European conflicts-law regulations in the United Kingdom (UK). Nevertheless, common remains highly influential numerous jurisdictions. In many legal systems, private-international-law are based fundamentally on developed courts. This is problematic since may be outdated. article examines choice-of-law – more specifically, and principles concerning determination tacit choice commercial contracts. traditional position compared selected jurisdictions namely, Australia, Canada, India, Israel New Zealand. Finally, highlights progress (or lack thereof) aforementioned addressing issues related