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Third (Anglo-Common Law) Countries and Rome II: Dilemma or Deliverance?

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Abstract:

This article addresses the significance of the adoption of Rome II by the UK for non-EU Anglo-Common Law ("third") countries. In the first part the potential comparative or "export" value of Rome II is explored with reference to the unique EU context within which Rome II operates. This is followed by an analysis and application of the Rome II general conflicts regime for torts (Article 4) to two Anglo-Common Law cases, Neilson v Overseas Projects Corporation of Victoria Ltd (High Court of Australia) and Harding v Wealands (House of Lords). In both cases the application of Rome II would have led to different reasoning and/or results. The author argues that valuable comparative insights may be gained through engagement with Rome II by third countries.
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