n Tydskrif vir die Suid-Afrikaanse Reg - A modest defence of renvoi : aantekeninge

Abstract

Renvoi thus arises from the fact that different legal systems have different choice of law rules. It will exist until that utopian day when the choice of law rules of all states are identical (and interpreted identically). It is thus a profound problem inherent in the choice of law approach to private international law. It must be grappled with by any serious student of private international law.