CREDIT LYONNAIS V NEW HAMPSHIRE INSURANCE CO

(1997) 6 Re LR 121

Queen’s Bench Division (Commercial Court)

Before Miss B Dohmann QC (sitting as a Deputy Judge of the High Court)

Conflict of laws - Contract - Proper law - Policies issued on behalf of US insurer in England by English underwriting agency to UK business enterprise of French multinational company - Policies part of worldwide scheme but concerned entirely and expressly with reference to that UK business - Whether contract or worldwide scheme must be shown to be more closely connected with law governing contract - Whether fact that multinational might dictate precise terms of local supply contracts meant that such contracts were governed by law of headquarters of that multinational - Whether presumption in favour of English law rebutted.