判决理由
The proper law of a contract is the system of law with which the transaction has its closest and most real connection, determined objectively where the parties have not made an express choice.
事实
A Liberian company and a Kuwaiti insurer disputed the proper law of a marine insurance policy issued in Kuwait but based on Lloyd's standard form.
判决摘要
The House of Lords held that English law was the proper law, as the policy was in standard Lloyd's form and the relevant maritime law connection was English.
关键引述
"The proper law of a contract is the system of law by reference to which the contract was made."
— Lord Diplock
后续处理
Applied
Applied in pre-Rome I cases on proper law determination.