“… There are two preliminaries to any consideration of a choice of law and jurisdiction. The first is to understand that law and legal systems are by their very nature local and parochial. There are more than 200 legal systems in the world, and they are almost all operated in the local language of the country in question, by judges who generally only speak that language, and they have developed to serve the needs and interests of the local population. It is essentially unusual to have a legal system that serves the needs, let alone the interests, of international business parties …” (more)
Sir Geoffrey Vos, the Chancellor of the High Court of England, and Wales, ‘The Future for the UK’s jurisdiction and English law after Brexit’, 13 May 2019. Presentation to a Seminar in Munich hosted by Münchener Juristische Gesellschaft, and the British Chamber of Commerce in Germany Justizpalast, München.