Novel aspects of the proposed African Principles on the Law Applicable to International Commercial Contracts

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Abstract

Although the African Principles are based mainly on the Rome I Regulation and the Hague Principles, there are substantial differences between the instruments. In future hard- or soft-law codifications of private international law of contract, on a national, regional or supranational level, whether in Africa or beyond, or even on the international level, the formulations used in the African Principles could perhaps be considered by the respective legislatures or formulating agencies. Such codifications include a possible future international instrument of the Hague Conference on Private International Law, probably in the form of a model law, that could conceivably be called the Principles on the Law Applicable to International Commercial Contracts, further identified as the Hague Principles on the Law Applicable to International Commercial Contracts,93 or the HCCH Principles on the Law Applicable to International Commercial Contracts.

Original languageEnglish
Pages (from-to)247-257
Number of pages11
JournalTydskrif vir die Suid-Afrikaanse Reg
Volume2024
Issue number2
DOIs
Publication statusPublished - 1 Apr 2024

ASJC Scopus subject areas

  • Law

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