HISTORY Until the middle of the 19th century, the courts applied the lex loci contractus or the law of the place where the contract was made, to decide whether the give contact was valid. The apparent advantage of this approach was that the rule was easy to apply with certain and predictable outcomes. Unfortunately, it was also open to abuse, e.g. the place could be selected fraudulently to validate an otherwise invalid contract; it might lead to application of laws with no real connection w...
