Homawoo v GMF Assurances SA [2010] EWHC 1941 (QB); [2011] EUECJ C-412/10

Jurisdiction: A short introduction to Rome II

Charles Dougherty and Marie Louise Kinsler look at the scope and impact of the rules Commercial parties will need to consider the scope of choice of law clauses and whether they are wide enough to encompass a non-contractual as well as contractual choice of law.On 11 January 2009, Regulation (EC) 864/2007, on the law applicable …

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Foreign Accidents And Foreign Law: Where are we now?

Philip Mead contemplates issues of jurisdiction ‘Case management judges should be astute to identify on the pleadings what the scope of any dispute as to the content of foreign law is, before launching into the need for foreign expert evidence.’ Ever since FBTO Schadeverzekeringen NV v Odenbreit [2007], claimant lawyers have been alert to the …

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