ABSTRACT

More energy has been expended in the discussion of tort cases in private international law in the common law world than on any other area of the subject.1 For English law, this was somewhat surprising,2 as the number of cases in the law of tort giving rise to conflicts problems had, until recently, been very limited indeed. However, it was accepted that the common law choice of law rules in respect of tort claims were one of the least satisfactory parts of the conflict system.3 The problems in this area are considerable and it remains to be seen if the recent legislative changes will provide a more satisfactory legal framework.4