English law has traditionally had separate choice of law rules for torts, restitution and equitable obligations. These rules have been largely replaced by Regulation ((EC) No 864/2007) on the law applicable to non-contractual obligations (Rome II). This chapter is primarily concerned with the Regulation but, before turning to examine this in detail, it is useful to say something about the problems involved in ascertaining the applicable law for non-contractual obligations and how English law solved these problems prior to the introduction of the Regulation. The...
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