ABSTRACT
This chapter deals with the conflict of laws, and more particularly the question of which law applies to (multimodal) contracts of carriage in the absence of conventional rules. As different countries have different rules of private international law, it is almost impossible to give an all-encompassing overview. The common law countries will therefore apply their common law rules of private international law. Once the applicable law has been established in accordance with the rules of private international law of the court seized, that law applies to the contract with the exception of its rules of private international law. Commercial contracts will often contain an express choice of law. The key difference between the implied choice of law and the establishment of the law with the 'closest and most real connection' is that the contracting parties in the latter case never intended to make any choice of law at all.
