It is obvious that circumstances will occasionally arise in which the law of the forum must be preferred to the foreign law that would normally be applicable to the case. An outstanding example of this is the civil law doctrine of ordre public under which any domestic rule designed to protect the public welfare must prevail over an inconsistent foreign rule. The danger of a doctrine so vague as this is that it may be interpreted to embrace such a multitude of domestic rules as to provide a fatally easy excuse for the application of the law of the forum and thus to...
Users without a subscription are not able to see the full
to access all content.