Whose law is it anyway?

For contracts with foreign suppliers, deciding which laws apply can have a major impact on the result of any disputes. Alan Ma looks at two recent cases

Two recent cases show how the rights and obligations of parties under an international contract depend on which law governs their agreement. In Aeolian Shipping SA v ISS Machinery Services (2001), Aeolian bought a turbo charger from a Japanese company via ISS. A separate contract was signed for ISS to supply spare parts.

The charger failed and Aeolian contacted...

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