Abstract
The lodestar of contract conflicts, i.e., the principle of party autonomy,1 has long been controversial in Latin-American legal literature and practice.2 This principle is of course irreconcilable with the classical Savignian approach, which authors and courts throughout the subcontinent still profess to follow.3 Such doctrinal scruples, however, did not stop European courts from adopting it for the simple reason that party autonomy is indispensable for the conduct of international trade and commerce. Indeed, it is difficult to envision a safe and orderly conduct of business across national borders-in Kozolchyk's terms a juridical road on which the free flow of goods
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