17) In 2008, the High Court in the Pfeiffer (18) case held that the
lex loci delicti should apply without exception as the governing law for an interstate tort (19) and limitation periods and damages should be considered as substantive matters for this purpose.
The
lex loci delicti choice of law test adopted by the High Court in Zhang seems meaningless if the court in the place of the wrong has no jurisdiction to hear the case, and consideration of the renvoi rules in that legal system seems doubly meaningless in such circumstances.
35) Formal validity of marriage is governed by the
lex loci celebrationis.
El lugar del dano se localizara en supuestos de danos a distancia, en el
lex loci damni--en virtud de lo dispuesto en el articulo 4.
Then comes the
lex loci laboris' principle: companies must guarantee their posted workers "hard core" mandatory protection rules - involving work schedules, paid leave, minimum wage, health and safety - in the host country.
The void, if any, was a byproduct of the era's prevailing common law choice of law rule,
lex loci delicti.
De esta manera, emplearian el metodo conflictual o la regla de conflicto de su foro, que en la mayoria de los casos es la
Lex Loci Executionis, o lugar de ejecucion del contrato (Aljure, 2000, p.
With regard to choice of law, the Defendants reject the use by the courts below of the
lex loci delicti test.
Germany) examines law related to international copyright, looking at the application of the territoriality principle and the
lex loci protectionis rule in the US and Europe.
3) Initially, the increasing complexities surrounding this field of law led the majority of jurisdictions in the United States to follow the "traditional" choice of law rule in tort actions (also commonly referred to as
lex loci delicti) (4) embodied in the original Restatement of Conflict of Laws: "the substantive rights and liabilities arising out of a tortious occurrence are determinable by the law of the place of the tort.
IV Recognition of Foreign Marriages not Complying with the
lex loci celebrationis
26 of the Rome II-Regulation states that "regarding infringement of intellectual property rights, the universally acknowledged principle of the
lex loci protectionis should be preserved".
