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Rome II: Difference between revisions
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{{box|This agreement and any non-contractual obligations arising out of or in connection with it are governed by English law.}} | {{box|This agreement and any non-contractual obligations arising out of or in connection with it are governed by English law.}} | ||
Then you have the [[Rome II]] Regulation to blame. It was published on 31 July 2007 and applies to all {{tag|EU}} Member States (except {{tag|Denmark}}) . It aims to harmonise the conflict of laws rules applied by Member States when dealing with disputes involving non-contractual obligations and means that one rule for choice of law in such disputes applies across all Member States. | Then you have the [[Rome II]] {{tag|EU Regulation}} to blame. It was published on 31 July 2007 and applies to all {{tag|EU}} Member States (except {{tag|Denmark}}) . It aims to harmonise the conflict of laws rules applied by Member States when dealing with disputes involving non-contractual obligations and means that one rule for choice of law in such disputes applies across all Member States. | ||
===[[Non-contractual obligations]]=== | ===[[Non-contractual obligations]]=== | ||
In this context “[[non-contractual obligations]]” includes claims based on [[tort]] such as [[negligence]], breach of [[competition law]] and breach of [[statutory duty]]. But, brilliantly, it does not apply to non-contractual obligations arising under [[bills of exchange]], [[cheque]]s and [[promissory note]]s and other [[negotiable instrument]]s which arise out of their negotiable character. | In this context “[[non-contractual obligations]]” includes claims based on [[tort]] such as [[negligence]], breach of [[competition law]] and breach of [[statutory duty]]. But, brilliantly, it does not apply to non-contractual obligations arising under [[bills of exchange]], [[cheque]]s and [[promissory note]]s and other [[negotiable instrument]]s which arise out of their negotiable character. | ||