1. SP North and J Fawcett,Cheshire and North's Private International Law(hereafter “Cheshire & North“) (London, Butterworths, 13th ed), 533–34.
2. Cheshire & North, 553; Nygh,supran 2, 2–3;Restatement 2nd Conflict of Laws(St Paul, American Law Institute Pub, 1996), s 187.
3. This principle had been accepted in European countries for many years: see M Giuliano and P Lagarde, “Report on the Convention on the Law Applicable to Contractual Obligations” (hereafter “Giuliano & Lagarde Report”) OJ 1980 C282/1, 15–16. It has been adopted in the EC Convention on the Law Applicable to Contractual Obligations 1980 (Rome Convention), Art 3. For more international conventions, see United Nations Convention on Contracts for the Inter national Sale of Goods (1980), Art 6; Hague Convention of 15 June 1955 on the Law Applicable to International Sales of Goods (Hague Sales Convention 1955), Art 2; Hague Convention of 22 December 1986 on the Law Applicable to International Sales of Goods 1986 (Hague Sales Convention 1986), Art 7; Inter-American Convention on the Law Applicable to International Contracts 1994 (Inter-American Convention), Art 7.1.