Abstract
This chapter deals with what the choice of English law as the applicable law may mean in a contract drawn up in the civil law tradition between parties from civil law countries. It discusses the differenced on issues like good faith and public policy. The chapter further raises the questions whether the operation of a domestic law in an international contract, chosen by the parties or not, is the same as the operation of the same law in a domestic contract, and of the position of lex mercatoria.
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