Volume III: Private International Law | Chapter 12 (1991): Operation of Foreign Public Law
Completed September 1989, with some additions to 1 Feb. 1990.
Hans W. Baade
A. Foreign Public Law as the Lex Causae
66. “Sovereign” or “public” rights. – Choice-of-law rules operate conventionally by private-law categories such as contracts or property or by sub-categories thereof (e.g. credit transactions or acquisitive prescription). Foreign public law, we have seen, readily enters into this scheme as a datum, as a determinant of pr…