Overview

All countries have their own sets of regulations and legal frameworks which are established and developed in accordance with their own legal cultures and traditions. As such, in order to resolve certain private matters that involve cross-border aspects (e.g., marriages or business transactions) and where the courts of different countries claim jurisdiction over cases, Conflict Law, which is also known as Private International Law (“PIL”), needs to be implemented in order to seek resolution.[1]

In practice, PIL not only determines the jurisdiction of a court in relation to certain cross-border private cases but also determines which country’s laws should be used in order to determine a given dispute (applicable law) or whether a judgment that was handed down in a foreign court can be recognized and enforced within a different jurisdiction.[2]