Abstract
THE unique contribution of American conflict of laws to modern ideas on choice of law is the introduction of governmental interest analysis to solve the perennial problem of which law to apply. Whilst this approach has been used extensively in several areas of choice of law in America it is only in tort choice of law that it has found favour in England. In this particular sphere interest analysis is advocated not only by English academics' but, even more importantly, by at least one Law Lord in the leading case of Boys v. Chaplin. 2 With the likelihood of reform of our tort choice of law rules in the near future it is appropriate to consider whether it is desirable or even possible to apply interest analysis in England to this area. In answering these questions it is proposed first to look at interest analysis as a means of arriving at particular decisions and secondly to consider the wider consequences for us in England of adopting interest analysis.
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