Description
Bloomsbury Publishing (UK) Place of Performance: A Comparative Analysis by Chukwuma Okoli
This book provides an unprecedented analysis of the place of performance. The book challenges the approach of the European legislator for not explicitly giving special significance to the place of performance in determining the applicable law in the absence of choice for commercial contracts. It also contains an analogy to matters of foreign country mandatory rules and the coherence between jurisdiction and choice of law. It concludes by proposing a revised Article 4 of Rome I Regulation which could be used as an international solution for those who wish to reform their choice of law rules.