Abstract

This article tries to introduce and analyses the newest EC Regulation Rome II on the applicable law to noncontractual obligations. It discusses the considerations of this legislation, the domain of its application, the applicable law of torts/delicts, unjust enrichment, negotiorum gestio, and culpa in contrahendo. We notice that the introduction of the new connecting factor, i.e. the place of the manifestly closer connection, will harmonize the theories of conflict of laws in Civil Law system and in Common Law system. And, the resort to the principle of party autonomy in the domain of noncontractual obligations will promote a pluralistic way of theories of conflict of laws.

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