TOVARLAR, ISHLAR VA XIZMATLAR NUKSONLARI NATIJASIDA YETKAZILGAN ZARARNI QOPLASHNING KOLLIZION TARTIBGA SOLINISHI

Authors

  • Salimova Nozanin Muxtorjon qizi Toshkent davlat yuridik universiteti Xalqaro huquq va inson huquqlari magistratura bosqichi talabasi Author

Abstract

This annotation explores the conflict of laws (private international law) mechanisms governing the compensation for damages arising from defects in goods, works, and services. It examines key principles such as lex loci delicti (law of the place where the tort occurred), lex loci contractus (law of the place where the contract was made), and party autonomy in choice-of-law clauses. The discussion highlights international conventions like the Rome II Regulation (EU) and the Hague Convention on Products Liability, addressing jurisdictional issues, applicable law determination, and cross-border enforcement of judgments. Emphasis is placed on consumer protection, harmonization efforts, and challenges in global supply chains, providing insights into resolving multinational disputes efficiently.

References

Dointjer Tebbens. International Product Liability: а Study of Comparative and International Legal Aspects of Product Liability. T.M.C. Asser Institute. Hague, 1979.

Michael I. Krauss. Product Liability and Game Theory: One More Trip to the Choice-of-Law Well. BYU L. REV. 759, 775-76 (2002).

Toshiyuki Kono. Critical and Comparative Analysis of the Rome II Regulation on Applicable Laws to Non-contractual Obligations and the New Private International Law of Japan.

Symeon C. Symeonides. The Quest for the Optimum in Resolving Product Liability Conflicts.

Peter Hay. Contemporary Approaches to Non-Contractual Obligations in Private International Law (Conflict of Laws) and the European Community’s “Rome II” Regulation.

David F. Caves. The Proper Law of Producers’’ Liability. Contemporary Problems in the Conflict of Laws

World-Wide Volkswagen Corp. v. Woodson, 444 U.S.

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Published

2025-12-05