Part 1 General and Special Reports, 1 General Comparative Report: Global Perspectives on the Hague Principles

Abstract

This chapter presents the General Comparative Report, which addresses, article by article, the Hague (or HCCH) Principles on Choice of Law in International Commercial Contracts of 2015 (the Hague Principles). The General Comparative Report compares the Hague Principles with the state of the law in over sixty jurisdictions worldwide and with supranational rules and soft law principles. It aims to encourage legislators, courts, practitioners, and academics to further develop their domestic private international law systems and possibly benefit hereby from the Hague Principles by consistently and adequately applying, interpreting, and amending domestic, supranational, and regional private international law (PIL) in the context of party choice of law. The chapter then details the structure of the Report and the questionnaire used to address the issues covered by the Hague Principles. It also provides an introduction and a comparative overview of each of the Articles of the Hague Principles.