A COMPARATIVE STUDY OF THE LAW GOVERNING CIVIL RESPONSIBILITIES IN BRITISH AND FRENCH PRIVATE INTERNATIONAL LAWS

Résumé

Nowadays the relationships between different countries and their citizens have expanded to the extent that currently it is not possible for any nation to stay surrounded by the walls of its land. By taking a look at the elements of international relationships, transportation of individuals from one country to another and, international commerce it can be concluded that there are countless international issues that could be faced. One of these issues is the issue of the law governing out-of contract responsibilities in case of a conflict between the laws. In these cases, there are no universal regulations and the basics of out-of contract civil responsibilities differ from one country to another. On this basis the issue is to determine the governing law in case of occurrence of a conflict regarding out-of contract responsibilities; in addition the issue is raised from disagreements between the domestic laws of different countries. This is because the verdict depends upon the governing law. Determining the law governing the civil responsibility has been one of the cases of conflict of laws in laws of Britain and other countries as well.