CLASSIFICATION IN PRIVATE INTERNATIONAL LAW
AbstractThe continuation of an article in an earlier issue, this article covers two instances of classification in international private law. First, the author considers the scope of the reference to the law of a foreign country by the conflicts rule of the forum on some juridical aspect of the facts. He examines three possible meanings for “the law of France” in this situation. Second, he studies the two main opposing theories of the constitutional nature and source of the rules of private international law, and their significance to principles developed in earlier sections of this article. The two theories are the "vested rights" theory and the "local rights" theory.
Keywords:Conflict of Laws
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