ABSTRACT
A.4 When international carriage cases come before courts in the United Kingdom, they are characterized not simply as ‘‘contracts’’ but as ‘‘international contracts of carriage’’.17 This characterization triggers the courts to apply a ‘‘unilateral’’ conflicts rule in favour of the appropriate convention as enacted in the lex fori.18 The convention appropriate depends on connecting factors. For CMR it suffices that just one of the states is a contracting state: Article 1.1. Thus, in practice, CMR extends to eastern Europe and the Middle East. However, the air regimes are more restricted: both place of departure and place of destination must be in contracting states: Article 1.2. The same is true of CIM 1980 and 1999: Article 1.1. All the regimes can be extended by national legislation to internal movements, in the United Kingdom this is the case of the air regimes,19 as well as by voluntary adoption by contracting parties.
