Conflict of laws

Iran Continental Shelf Oil Co v IRI International Corporation [2002] EWCA, Court of Appeal, Ward, Clarke and Carnwath LJJ, 28 June 2002

Conflict of laws – Sale of goods – Applicable law – No express choice of law clause in agreement – Place with which contract was most closely connected – Presumption in favour of place of business of party whose performance characterised contract – Characterising performance in case of contract for sale of goods – Whether UK office was seller’s relevant place of business – Whether presumption in favour of England rebutted – Rome Convention 1989, arts 4(2) and 4(5)