COMMERCIAL MARINE & PILING LTD v PIERSE CONTRACTING LTD
[2009] Lloyd's Rep Plus 87
QUEEN’S BENCH DIVISION (TECHNOLOGY AND CONSTRUCTION COURT)
Before Mr Justice Ramsey
Conflict of laws - Jurisdiction - Guarantee - Irish company guaranteeing debt owed in England - Whether obligation in question to be performed in England - English law applicable to guarantee - Debtor required to seek out creditor - Rome Convention 1980, article 4.2 and 4.5 - Council Regulation EC (No) 44/2001, article 5.