Lex causae: Literally, the law applicable to the case 准据法
Lex actus: The law of the transaction, i.e., briefly, the
internal law of the country with which the transaction is most closely
connected. It is sometimes used with the same meaning as Lex loci
actus 行为地法
Lex loci actus: the law of the place where a transaction is
concluded; in relation to the conclusion of a contract called Lex loci
contractus and to the celebration of a marriage, lex loci
celebrationis. 行为发生地法
Lex loci contractus: the internal law of the place where the
contract is entered into.合同缔结地法
Lex loci solutionis: the law of the place of performance (of a
contract)合同履行地法
Lex loci delecti commissi: the law of the place where a tort is
commited.侵权行为地发生法
Lex loci celebrationis: the law of the place where a marriage
is celebrated.婚姻缔结地法
Lex domicillii: the law of a person's domicile.住所地法
Lex fori: the law administered by the court hearing the case.法院地法
Lex situs: the law of the place of where property is situated.物之所在地法
Lex patriae: national law当事人本国法
Lex personalis: 属人法
Conflict of laws refers to the situation in which a certain civil
legal relation with foreign elements involves the laws of two
different legal units which conflict with each other.
It is generally accepted that choice of law is done in two stages:
(a) Classification or characterization of the cause of action.
(b) The identification of the relevant system of law by means of a
connecting factor.
II. Causes Giving Rise to Conflict of Laws
1. Citizens of different States have extensive economic, cultural
and civil contacts among themselves;
2. The countries concerned grants civil legal rights to citizens
of other countries;
3. The countries concerned recognize the legal force of other
countries' civil and commercial laws;
4. Laws of the countries concerned have different provisions
concerning the same matter.
These conditions must all exist for the rise of conflict of
laws; lack of any one of them would remove the possibility of
conflicts of laws.
In what circumstances do you think that civil legal relations with
foreign elements do not involve conflict of laws?
III. Civil legal relations with foreign elements that do not involve
conflict of laws:
If the provisions of laws of countries concerned are the same
regarding the same matter;
If the civil legal relation with foreign element is regulated by
uniform substantive laws such as international custom or treaties to
which countries concerned are parties;
If the civil legal relation with foreign element is regulated by a
specific substantive municipal law of a country.
Settlement of Conflict of Laws
Conflicts of laws are usually resolved by applying conflict rules as
provided in a country's private international law; or by applying the
conflict rules as provided in the uniform rules of international
treaties binding countries concerned.
By applying the conflict rules, the inevitable result is one of the
following three:
1. The law the parties have chosen;
2. The substantive law of the forum State when the conflict
rule points to that State's own law;
3. A foreign country's substantive law when the conflict rule
points to that country's law, or when that country's law has the
closet connection with the case.
Article 143 If a citizen of the People's Republic of China settles in
a foreign country, the law of that country may be applicable as
regards his capacity for civil conduct
Conflict rules are a special kind of legal rules whose function is not
to provide directly the rights and obligations of the parties, but
rather to point to a certain country's law as the law applicable to a
particular case.
General rules
1. Questions concerning legal capacity or competence shall be governed
by the law of the parties' domiciles.
E.g.: Capacity to marry is governed by the law of the parties' domiciles.
2. Ownership of immovable property is governed by the lex situs
3. the formal validity of marriage is governed by the law of the place
of celebration
4. Procedure is governed by the lex fori
5. Contracts are governed by (in general) by the law intended by the parties
Sources of conflict rules:
1. A country's laws regarding foreign economic and civil affairs;
e.g. Chapter 8 of China's General Principles of the Civil Law;
2. International treaties;
3. Judicial precedents ( for common law countries)
Structure of a Conflict Rule
Legal category 范围 (Sometimes called "operative facts"起作用的事实)
e.g.: the formal validity of marriage is governed by...
Legal categories are like pigeon-holes into which the legal issue
disclosed by the facts of cases may be placed.
Attribution（系属）( Connecting words/factors + the applicable law):
Lex loci celebrationis, lex domicilii, lex fori, law
chosen by the parties themselves etc.
At the core of the attributions are the connecting factors
such as loci celebrationis, loci domicilii, fori, loci contractus,
loci solutionis, loci actus, situs etc.
connecting factors connect the legal categories to the applicable law.
The personal law / lex personalis
a) Law of nationality / lex patriae
b) Law of domicile / lex domicilii
That of the natural person and that of the juristic person
2. Lex situs / law of the place where the property is situate;
3. Lex loci actus / law of the place where the act is performed
a) Lex loci contractus
b) Lex loci solutionis
c) Lex loci delicti commissi
d) Lex loci celebrationis
4. Lex fori / law of the forum
5. Law of the flag
6. Lex voluntatis / law chosen by the parties
7. The law which has the closest connection with the case.
Types of Conflict Rules
Depending on the attributions, conflict rules can be divided into the
following types:
1. Unilateral conflict rules
2. Bilateral conflict rules
3. Cumulative conflict rules
4. Alternative choice of law rules
Conditional
Unconditional
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