ABSTRACT
Every contract stipulates that the law of contract is the law of the country where the contract is executed; in other words, the country where the Plant/Project is built. Surprisingly, the law of the country, in turn, refers to the UN Law. As the English law is popular, many contracts stipulate the English law as the law of Contract. When the Owner and the Contractor are from two different countries other than England, the English law is seen as a neutral country law.
If a Vendor of Contractor belongs to a country where manufacturing of the equipment related to the Project takes place, then the law applicable under Purchase Order is the law of the Vendor’s country and CISG law of UNCITRAL, not the law of the country where the Project is built.
