Acta Universitatis Danubius. Juridica, Vol 6, No 2 (2010)

Abstract

An intensive increase in international goods and services exchange has caused the appearance of a growing number of torts legally and factually related to two or more countries.
Tortious liability is defined by internal regulation of  international private law, certain international treaties and in some legal systems by court practices. Legal consequences of unlawful actions from which damage arises in potentially applicable internal law are often very different so that in the process of the decision on the merits the competent bodies face the problem of the conflict of laws. Conflict of law solutions of internal law most often rely on the application of the law of the place of a tortious act and law of the place where the event giving rise to the damage occurred. The development tendency of the conflict of law regulation is directed towards abandoning fixed solutions such as the application of lex loci delicti commissi and the acceptance of the rule of the closest connection as an alternative or exclusive solution.