Introduction

Choice of law clauses are now a firmly established feature of international agreements. Their impact however goes beyond the question of what rights and remedies a party may enjoy, but also strikes to the very fundamental question: how will a tribunal (or court) interpret the words of the contract in the first place? This significance to choice of law selection is often glossed over in contracts and there is a tendency to assume that one common law system treats the question of contractual interpretation much the same as any other. An example of this attitude may be found in the ...