ABSTRACT
The parties to the Brussels Convention are States in the sense of international law and, thus, jurisdiction is allocated to the courts of international States rather than to individual legal systems. For the UK, therefore, the Conventions do not distinguish English law, Scots law or the law of Northern Ireland. In some cases, for example, where the special jurisdictional rules apply, the localising job may have been done incidentally but, in other cases, for example, where jurisdiction is based on the wide concept of domicile used in the Conventions, it will not. To deal with these issues, the Modified Convention was introduced.156 This goes further than was necessary simply to make the Brussels Convention operative within the UK and, in effect, produces a code for the general allocation of conflict cases based on the Brussels model.
