By Amos Shapira M. Jur. (Jerusalem), M.C.L. (Columbia), J.S.D. (Yale) (auth.)

This booklet is predicated on a doctoral thesis submitted to Yale college legislation university in 1968. I desire to recognize my inner most gratitude to my large­ visor within the writing of the thesis, Professor Ronald M. Dworkin, whose in­ attractions and feedback have conspicuously contributed to the current paintings. many times i've been encouraged through the guidelines expressed by means of hirn either in own discussions and in his clash of legislation and Jurisprudence classes. it's been my privilege additionally to have had Professors Leon S. Lipson and Guido Calabresi as supervisors. i've got derived nice make the most of their sug­ gestions. A clearly feIt appreciation is expressed to all 3 folks. a distinct debt of gratitude is due to the Yale legislations tuition for the gener­ ous monetary aid prolonged to me. I additionally desire to list my indebtedness to the Hebrew college of Jerusalem and to Tel-Aviv college for his or her monetary information. i'm super thankful to Mr. Michael Reiss, '68 Yale legislations institution for his major editorial advice. thank you also are as a result of my spouse Ettie for important support and encouragement. ultimately, I desire to thank the publishers for his or her courtesy and cooperation. A.S.

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Extra resources for The Interest Approach to Choice of Law: With Special Reference to Tort Problems

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122 The ascertainment of the loeus delieti is an important feature of the English doctrine, albeit not to such a degree as under the American placeof wrong rule. 123 In arecent publication two English scholars embarked upon an exhaustive exploration of the problem of localization. Interestingly enough, they came up with an unreserved recommendation in favor of the American "last event" rule. l24 The double-limb rule has been consistently subjected to vigorous academic criticism in England. It is deplored by some writers as being generally undesirable, stemming from an unfortunate misunderstanding of the language of Phillips v.

See Ehrenzweig, supra note 12, at 717. Cf. Cavers, supra note 9, at 120 n. 52. 28 Distinctions were attempted notably with regard to the "local public policy" and "domicile" concepts and the problem of proving foreign laws. Some American jurists endorsed the idea of no, or at least limited, applicabillty of the local-public-policy doctrine in interstate litigation owing to the profound sense of unity among sister-states of a federal union. However, this proposed distinction was more an expression of an aspired ideal than really accounted for by the actual holdings of courts.

85 CURRIE, supra note 72, at 52. 86 Id. at 616. 87 Id. at 138. 88 Id. at 140. 89 Id. at 161. 90 See generally COOK, THE LOGICAL AND LEGAL BASES OF THE CONFLICT OF LAWS (1942). The locallaw theory has usually been attributed to both W. W. Cook and Judge Learned Hand. It was, however, suggested that there were in effect two distinct versions of this theory, one identified with Cook and the other with Judge Hand. The latter version was criticized as still tainted with Vested Rights conceptuality. See Cavers, Comment: The Two "Local Law" Theories (1950) in AALS READINGS 124, 127.

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