Abstract
The article contains an analysis of the conflict of laws regulation of obligations arising from negotiorum gestio. Within the framework of the study, much attention is paid to both substantive and conflict-of-laws factors that complicate the construction of an optimal regulatory model. From the perspective of comparative legal analysis, the main approaches and modalities of regulation are determined, their critical analysis is conducted with due regard for the positions of the European courts, as well as legal gaps in the Russian legal order are specified. The author comes to the conclusion about the expediency of reforming the current Russian legislation, formulates proposals for the diversification of conflict-of-laws regulation based on the typification of cases of negotiorum gestio. The author also attempts to identify ways to eliminate legal uncertainty for the parties from a practical point of view within the framework of existing regulation in the context of the potential applicability of the statute of unilateral transactions, representation, unjust enrichment and tort conflict of laws rules.
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