APPLICABLE LAW ON CONTRACTUAL OBLIGATIONS IN EUROPEAN UNION AND AMERICAN LAW

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MAFI HOMAYOUN; TAGHIPOUR MOHAMMAD HOSIN

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Journal: PRIVATE LAW Year:2016 | Volume:4 | Issue:13 Page(s): 147-179

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Information Journal Paper

Title

APPLICABLE LAW ON CONTRACTUAL OBLIGATIONS IN EUROPEAN UNION AND AMERICAN LAW

Author(s)

MAFI HOMAYOUN | TAGHIPOUR MOHAMMAD HOSIN | Issue Writer Certificate

Keywords

APPLICABLE LAWQ3

CONTRACTUAL OBLIGATIONSQ2

ROME I REGULATIONQ1

EUROPEAN LAWQ1

AMERICAN LAWQ1

Abstract

In EU and AMERICAN LAW, the principle of autonomy has been recognized. For the purpose of unification, Rome 1 Regulation allows parties to choose the law that has no link to the contract. By contrast, in AMERICAN LAW, the selected law is required to have a basic or reasonable relationship with the contract. According to Rome 1 Regulation, the chosen law does not affect the application of overriding mandatory provisions of the law of the forum and the law of the performance of the contract. In AMERICAN LAW, the chosen law should not be in conflict with public policy of the forum and a fundamental policy of a state which has, substantially, greater interest than the chosen state in relation to the determination of a particular issue. This article examines the positions of European Union and AMERICAN LAW regarding the determination of APPLICABLE LAW.

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APA: Copy

MAFI, HOMAYOUN, & TAGHIPOUR, MOHAMMAD HOSIN. (2016). APPLICABLE LAW ON CONTRACTUAL OBLIGATIONS IN EUROPEAN UNION AND AMERICAN LAW. PRIVATE LAW, 4(13 ), 147-179. SID. https://sid.ir/paper/252695/en

Vancouver: Copy

MAFI HOMAYOUN, TAGHIPOUR MOHAMMAD HOSIN. APPLICABLE LAW ON CONTRACTUAL OBLIGATIONS IN EUROPEAN UNION AND AMERICAN LAW. PRIVATE LAW[Internet]. 2016;4(13 ):147-179. Available from: https://sid.ir/paper/252695/en

IEEE: Copy

HOMAYOUN MAFI, and MOHAMMAD HOSIN TAGHIPOUR, “APPLICABLE LAW ON CONTRACTUAL OBLIGATIONS IN EUROPEAN UNION AND AMERICAN LAW,” PRIVATE LAW, vol. 4, no. 13 , pp. 147–179, 2016, [Online]. Available: https://sid.ir/paper/252695/en

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