Abstract:
Historically, tort choice of law has been one of the most unsettled areas of private international law in Anglo-common law jurisdictions. Two controversial decisions by superior courts in the past decade, namely the High Court of Australia in Neilson v Overseas Projects Corporation of Victoria Ltd and the House of Lords in Harding v Wealands, have left the Anglo-common law world somewhat baffl ed and perplexed, giving rise to lively discussion amongst confl icts commentators and renewed refl ection and focus on this area of the law.