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The examples you have given are interesting because they are recent and the province of international agreements. I wonder if English law is used widely in othe
by hkt 8y ago
The examples you have given are interesting because they are recent and the province of international agreements. I wonder if English law is used widely in other places and for different agreements as part of a legacy of empire?
- flexie 8y agoIn so far as the empire spread the English language. Otherwise, I am not so sure. I have never heard in a negotiation that a party wanted English venue with reference to the British Empire, respect of English courts or similar. It's simply more convenient due to the language. Usually it's a matter of negotiation. In a contract between a French and a German company, the French lawyer will suggest French law and venue, the German lawyer will suggest German law and venue. If either of them have sufficient bargaining power, it may very well prevail. Among equal parties, a compromise would usually involve selecting a "neutral" legal system and venue. English is the language everyone knows, so usually English is chosen. It's not always UK. Sometimes it Hong Kong or Singapore (typically if a party is Asian). Sometimes it's New York. Generally, European lawyers are wary of American courts and American law with its exotic remedies such as punitive damages. Also, between Europeans it seems unnecessary to go to another continent for arbitration.