Contractual and non-contractuall obligations in private international Law

Contractual and Non-contractual Obligations in Private International Law This doctorate thesis deals with the European international private law and discusses the current law-crash modification of contractual and non-contractual obligations. Characteristic of the European community is the absence of unification of the substantive law, which is compensated, by the unification of conflict standards. The unification of conflict standards, as an instrument of the international private law, can be understood as a certain sign of unification of direct standards. Conflict standards do not govern directly the rights and obligations of the parties to a contract in international private law but they answer the question by which legal order the given relationship should be abided and therefore they provide certain degree of foreseeability and safety. The first (general) part called "European international private law - from conventions to regulations" is dedicated to development of the unification of conflict standards within the European community. At present, the unification of the conflict issue is represented by two new-adopted Roman regulations concurring to the Roman convention on the law applicable to contractual obligations. Analysis of the first Roman regulation on the law applicable to contractual..