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The Rome Convention on the law applicable to contractual obligations
 Uličník, Tomáš ; Kučera, Zdeněk (referee) ; Pauknerová, Monika (advisor)
Conclusion - 103 - Obsah The Rome Convention on the law applicable to contractual obligations well known also as "Rome Convention (1980)" or just "Rome I." came into force on April 4th, 1991. On the field of Private international law in the EU member states, the Rome Convention plays the most significant role regarding contractual obligations. The Purpose of the Convention was to establish and uniform the same rules for every participating country. It contains rules mainly connected with party autonomy and right to choose governing law for their particular contract and rules concerned with solving problems, when parties have not agreed on the choice of law clause in their contract (art. 4). This article has become crucial and also the most criticized throughout the whole Convention. It tries to put together two different principles: a) civil law is represented by a characteristic performance approach, in which courts of the given countries apply periodically and without many exceptions to find out the country to which the contract is most closely connected (art. 4/5), b) courts of the common law countries, on the other hand, prefer the rule of the proper law of a contract using wording of art. 4/1 and 4/5. The above mentioned issues and also the new possibility to harmonize private international law on the...
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