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Product Liability and Private International Law: Choice of Law in Tort in England

Product Liability and Private International Law: Choice of Law in Tort in England STUART DUTSON Produc t Liability and Private International Law: Choic e of Law in Tort in England I. INTRODUCTION The determination of whic h law should be applicable in interna­ tional product liability litigation is a problem tha t ha s often bedeviled th e court, jurists and practitioners alike. Whilst product liability problems can be entirel y domestic, th e natur e of th e design, manufac­ ture, supply, and consumption of products , and th e damag e tha t they can do if defective, is such tha t a product liability problem can involve a plethora of materia l international elements. The internationaliza­ tion of world trad e bears this out further — a consumer reaching for a piece of fruit or selecting a motor vehicle, or a business purchasing new equipment or obtaining intermediate goods, may well find that the product that it selected was manufactured overseas. Moreover, th e finished product may itself consist of a mix of domestic and for­ eign parts. The product or one or more of it s components may have been designed overseas and manufactured there or elsewhere. How­ ever, th e internationa l dimension in a product liability http://www.deepdyve.com/assets/images/DeepDyve-Logo-lg.png American Journal of Comparative Law Oxford University Press

Product Liability and Private International Law: Choice of Law in Tort in England

American Journal of Comparative Law , Volume 47 (1) – Jan 1, 1999

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Publisher
Oxford University Press
Copyright
© American Association for the Comparative Study of Law 1972
ISSN
0002-919X
eISSN
2326-9197
DOI
10.2307/841000
Publisher site
See Article on Publisher Site

Abstract

STUART DUTSON Produc t Liability and Private International Law: Choic e of Law in Tort in England I. INTRODUCTION The determination of whic h law should be applicable in interna­ tional product liability litigation is a problem tha t ha s often bedeviled th e court, jurists and practitioners alike. Whilst product liability problems can be entirel y domestic, th e natur e of th e design, manufac­ ture, supply, and consumption of products , and th e damag e tha t they can do if defective, is such tha t a product liability problem can involve a plethora of materia l international elements. The internationaliza­ tion of world trad e bears this out further — a consumer reaching for a piece of fruit or selecting a motor vehicle, or a business purchasing new equipment or obtaining intermediate goods, may well find that the product that it selected was manufactured overseas. Moreover, th e finished product may itself consist of a mix of domestic and for­ eign parts. The product or one or more of it s components may have been designed overseas and manufactured there or elsewhere. How­ ever, th e internationa l dimension in a product liability

Journal

American Journal of Comparative LawOxford University Press

Published: Jan 1, 1999

There are no references for this article.