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The Foundation of Choice of Law – Choice and Equality - Oxford Scholarship Online
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The Foundation of Choice of Law: Choice and Equality

Sagi Peari


This book focuses on the subject of choice of law as a whole and provides an analysis of its various rules, principles, doctrines, and concepts. It offers a conceptual account of choice of law, called “choice equality foundation” (CEF), which aims to flesh out the normative basis of the subject. This book reveals that, despite the multiplicity of titles and labels within the myriad choice-of-law rules and practices of the US, Canadian, European, and other systems, many of them effectively confirm and crystallize CEF’s vision of the subject. This alignment signifies the necessarily intimate rel ... More

Keywords: choice of law, choice, equality, theory and practice, party autonomy, most significant relationship, closest connection, public policy, international human rights, digital age

Bibliographic Information

Print publication date: 2018 Print ISBN-13: 9780190622305
Published to Oxford Scholarship Online: April 2018 DOI:10.1093/oso/9780190622305.001.0001


Affiliations are at time of print publication.

Sagi Peari, author
Visiting Scholar and Adjunct Faculty, Osgoode Hall Law School, York University