181 Contract, tort and bailment

| Commentary

(c) Choice of law

Identifying the law that governs a claim involving the cross-border loan of chattels depends primarily on the basis of the claim. When the UK was a member of the EU, claims for breach of contract before the English courts were governed by the provisions of the European Regulation on the law applicable to contractual obligations (‘Rome I’)1 and claims in respect of non-contractual

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