Oiling the machine: Overriding mandatory provisions and public policy in the Hague Principles on choice of law in international commercial contracts

Abstract

This article examines Article 11 of the Hague Principles on Choice of Law in International Commercial Contracts (2015), which concerns itself with the relationship between the system of law chosen by the parties and the laws and policies of other systems. It addresses, in particular, the Article's drafting history, its role within the Principles and its significance for the relationship between the Principles and the Hague Choice of Court Convention (2005).