oa Comparative and International Law Journal of Southern Africa - The classification and governmental interest approaches to choice of law and the American experience in torts
|Article Title||The classification and governmental interest approaches to choice of law and the American experience in torts|
|© Publisher:||Institute of Foreign and Comparative Law|
|Journal||Comparative and International Law Journal of Southern Africa|
|Affiliations||1 University of Exeter|
|Publication Date||Nov 1978|
|Pages||255 - 275|
|Keyword(s)||Babcock v Jackson, Choice of law process, Classification approach, Classification categories, Dym v Gordon, Governmental interest approach, Jurisdiction-selecting rule, Mertz v Mertz, South African Law and United States of America|
The thesis of this essay is that the entire methodology of the new approach is unsound from the practical no less than the theoretical viewpoint. In this respect, the question of the nature of choice of law as jurisdiction-selecting or rule-selecting must, indeed, be the point of departure.
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