THE ROME II REGULATION ON CHOICE OF LAW IN TORT

Abstract

The adoption on 11th July 2007 of EC Regulation 864/2007 on the Law Applicable to Non-contractual Obligations, also known as the Rome II Regulation, marks a major advance in the harmonization of private international law at European Community level. The Regulation complements the Rome Convention on the Law Applicable to Contractual Obligations (1980) by specifying harmonized choice of law rules for torts and restitutionary obligations. The present article attempts a critical analysis of the provisions of the Rome II Regulation in a comparative context. Reference is also made to relevant provisions