- Choice of law clauses — Rome Convention — Rome I Regulation and choice of law
This chapter explains Articles 14 and 15 of the Rome I Regulation. Article 14 provides conflict rules relating to voluntary assignments and contractual subrogation. Article 15 applies to subrogation by operation of law, where a third person has a ‘duty’ to satisfy the creditor and/or has in fact satisfied the creditor in discharge of that duty. In contrast to Article 14, which requires a voluntary, contractual subrogation of such a claim, Article 15 is engaged where the law imposes a duty on the third person to pay.
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