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

Volume 11, Issue 3
  • ISSN : 0010-4051



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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