Abstract
The characterization of Statutes of Limitation in private international law of France walked its own path. Originally the characterization in the issues with a foreign element had in France its own connecting factor of the debtor’s domicile. This rule was enshrined in the famous decision of the Court of Cassation of France of 1869. It was controversial, whether that characterization related to substance or procedure. In 1950 the Court of Cassation of France held as the alternative connecting factor the law applicable to the obligation (lex causae) and this was the beginning of the road to the substantive characterization which had been already established in German law. The Rome I and the Rome II Regulations of the European Union as well as the Article 2221 of the Civil Code of France amended in 2008 have fixed the substantive characterization of Statutes of Limitation in France on the legislative level. Keywords: private international law; characterization; statutes of limitation; debtor’s domicile; substance and procedure; lex causae; Court of Cassation of France.
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