COURSE MANUAL

INTERNATIONAL SALE OF GOODS LAW

Course Instructor:

Prof (Dr) Saloni Khanderia

Elective
This document is prepared by the course instructor and contains basic information relevant to the
execution of the course. It is the official record for all intends and purposes as far the elective
course, Comparative International Sale of Goods, is concerned.

This course manual can be used as a general guide to the subject. However, the instructor can
modify, extend or supplement the course (without tampering its basic framework and objectives)
for the effective and efficient delivery of the course. Albeit, the instructor will provide the
students with reasons for such changes.

Part I

Course Title: Comparative International Sale of Goods Law

Course Code:
Course Duration: One Semester (15 Weeks)
No. of Credit Units: 4 credits
Level: UG, PG or Both.
Medium of Instruction: English
Pre-requisites: The Law of Contract
Pre-cursors:
Equivalent Courses:
Exclusive Courses:
Part II

1. Course Description
International trade forms the catalyst for the development of the law on the transnational sale of goods. A
contract for the sale of goods is considered to be international when it consists of a transnational element
– namely when the parties belong to different nationalities or when the performance (in terms of the
delivery or the payment of goods) must take place overseas. It is in this context that international trade
forms the primary driving force for the development of the law on the global sale of goods.

While national governments have attempted to create suitable conditions for free trade within which
merchants may exchange goods, international trade has been burdened with conflicting regulatory
mechanisms. For this reason, legal scholars have justified the creation of a framework that varies from
that prevailing at the national level to regulate transactions on the international sale of goods on the
ground that domestic law must be restricted to regulating internal matters, which have no international
element. As such, the principles of domestic law are not naturally formulated to resolve disputes with
international characteristics – which must essentially be governed by agreement among sovereign nations.
This is because the rules and principles differ depending on the peculiarity of the legal system within
which, they are based – for instance, in a jurisdiction following the common law (the United Kingdom,
Australia, India) or, the civil law (the European Union, India’s BRICS partners – Brazil, Russia and
China). This phenomenon, in turn, explains why the principles on the international sale of goods have
been at the forefront when it comes to the harmonization and unification of various aspects of the law of
contract. The focus in recent times has shifted from the application of the domestic law at the
international level to the formulation of international instruments based on generally accepted standards
to regulate disputes arising in such matters. While some legal systems such as India have strongly resisted
these transformations, the rationale for this paradigm shift (in favour of unification) in other jurisdictions
has been two-fold. Firstly, to pronounce general and widely accepted international practices where
interested parties are ensured that disputes adjudicated according to the highest commercial standards.
Secondly, to drastically reduce costs involved in the enforcement of the law and increase predictability in
the application of the rules.

The attempts to regulate the international sale of goods involve treaties and conventions, which are
binding by nature. The United Nation’s Convention on the International Sale of Goods also referred to as
the Vienna Convention or the CISG serves as the most popular example. Among the non-binding
instruments (also known as soft law), the efforts of the UNIDROIT in framing the Principles on
International Commercial Contracts (PICC), the UNCITRAL in formulating the Model Law on
International Commercial Arbitration and Arbitration Rules and, the Hague Principles on Choice of Law
in International Commercial Contracts, deserves mention. The International Chamber of Commerce’s
INCOTERMS is also a valuable addition to the law on the international sale of goods. Lastly, the law
relating to the international sale of goods has been regulated via lex mercatoria, which may be defined as
autonomous rules operating individually from any national legal system.

2. Course Aims

The purpose of this course will be to:

 Understand the role and application of trade terms (ICC INCOTERMS) while drafting
international agreements on the sale of goods;
 Understand the mechanism to identify the law that will govern a dispute arising from the
international sale of goods in some major jurisdictions such as the EU, the UK, the BRICS, Japan
and the United States. This aspect would involve an examination of a) the parties’ right in
international law to pre-decide the applicable law, b) the extent to which, this right prevails in
determining the law in these jurisdictions, c) the applicable law in the absence of such an
agreement and, d) an in-depth examination of the rules for the application of the CISG (including
those which lead to its application before courts in the UK, India or South Africa, which are not
presently signatories to the instrument). In doing so, the students would additionally be able to
understand the factors that must be considered while drafting (or agreeing upon) choice of law
clauses in international contracts for the sale of goods.
 Understand the interpretation of international instruments and how it differs from that of the
national laws; and
 Predict the outcome of disputes which may arise before the courts in these jurisdictions. This
aspect would involve examining the circumstances which call for the termination of the contract
and/or the re-negotiation of the terms of the agreements and, the remedies available for non-
performance (such as the failure to perform or defective performance).
 Identify the gaps in the laws applicable in these jurisdictions and understand the different
mechanisms/provisions available in the form of soft-law to fill these lacunae at the time of
resolving such disputes. The different mechanisms to regulate international disputes arising from
the sale of goods between private persons.
3. Teaching Methodology

 Lecture method
 Readings
 Problem-solving
 Reasoning for judgments

4. Intended Learning Outcomes

Course Intended Learning Weightag Teaching and Assessment Tasks/

Outcomes e Learning Activities Activities

Understand the “conflict of 40% Readings;

law” issues in international discussion of case
contracts for the sale of goods Solving problem sets
law
Be able to assess the rights and 30% Solving problem sets and
liabilities of parties in deliberating the possible
international contracts for the Readings; discussion
verdict.
sale of goods. The discussion of relevant verdicts
would include the rights and of courts in
liabilities for injuries caused by international
defective products. jurisdictions
Assess the influence of soft 30% Solving problem sets
law instruments and determining if soft
Readings; discussion
law could plausibly be
of case law (if any)
relied upon to interpret,
that have relied upon
supplement and develop
soft law instruments
the relevant domestic law.
as gap fillers.

5. Grading of Student Achievement

Of the total score required to pass this course, a minimum of 50% shall be obtained by the
student in the course work (i.e., combined score of internal assessments and end semester
examination).

Grade Sheet
 Percentage Grade Grade Grade Description
of Marks Value

80 and above O 8 Outstanding – Exceptional knowledge of the subject

matter, thorough understanding of issues; ability to
synthesize ideas, rules and principles and extraordinary
critical and analytical ability

75 – 79 A+ 7.5 Excellent - Sound knowledge of the subject matter,

thorough understanding of issues; ability to synthesize
ideas, rules and principles and critical and analytical
ability

70 – 74 A 7 Very Good - Sound knowledge of the subject matter,

excellent organizational capacity, ability to synthesize
ideas, rules and principles, critically analyse existing
materials and originality in thinking and presentation

65 – 69 A- 6 Good - Good understanding of the subject matter,

ability to identify issues and provide balanced solutions
to problems and good critical and analytical skills

60 – 64 B+ 5 Fair – Average understanding of the subject matter,

limited ability to identify issues and provide solutions
to problems and reasonable critical and analytical skills

55 – 59 B 4 Acceptable- Adequate knowledge of the subject matter

to go to the next level of study and reasonable critical
and analytical skills.

50 – 54 B- 3 Marginal- Limited knowledge of the subject matter

and irrelevant use of materials and, poor critical and
analytical skills

Below 50 F 0 Fail - Poor comprehension of the subject matter; poor

critical and analytical skills and marginal use of the
relevant materials. Will require repeating the course

6. Criteria for Student Assessments

Internal assessment of the participants will be based on the following criteria. In case any of the
participants miss the IA tests, alternative internal assessments will be conducted (Please specify
the alternative assessment)

Assessment Weightage Remarks

One research 50 marks Students are required to write one research paper for
 Assessment Weightage Remarks
3000 words on a topic provided to them by the
instructor. Footnotes be according to the OSCOLA
paper
guidelines. Date of submission: 2 April 2024

End Term Assessment: 50 marks There will be an open-book end-semester

examination for all participants of the course who
Open-book for 1.5 hours have successfully completed the course work.
on the date announced
by the Exams office

Part IV

Course/Class Policies

Academic Integrity and Honesty

Learning and knowledge production of any kind is a collaborative process. Collaboration

demands an ethical responsibility to acknowledge who we have learnt from, what we have
learned, and how reading and learning from others have helped us shape our own ideas. Even our
own ideas demand an acknowledgement of the sources and processes through which those ideas
have emerged. Thus, all ideas must be supported by citations. All ideas borrowed from articles,
books, journals, magazines, case laws, statutes, photographs, films, paintings, etc., in print or
online, must be credited with the original source. If the source of inspiration of your idea is a
friend, a casual chat, something that you overheard, or heard being discussed at a conference or
in class, even they must be duly credited. If you paraphrase or directly quote from a web source
in the examination, presentation or essays, the source must be acknowledged. The university has
a framework to deal with cases of plagiarism. All form of plagiarism will be taken seriously by
the University and prescribed sanctions will be imposed on those who commit plagiarism.

Disability Support and Accommodation Requirements

JGU endeavors to make all its courses accessible to students. All students with any known
disability needing academic accommodation are required to register with the Disability Support
Committee [email protected]. The Committee has so far identified the following conditions that
could possibly hinder student’s overall well-being. These include: physical and mobility related
difficulties; visual impairment; hearing impairment; medical conditions; specific learning
difficulties e.g. dyslexia; mental health.
The Disability Support Committee maintains strict confidentiality of its discussions. Students
should preferably register with the Committee during the month of June/January as disability
accommodation requires early planning. DSC will approve of and coordinate all disability
related services such as appointment of academic mentors, arranging infrastructural facilities,
and course related requirements such as special lectures, tutorials and examinations.
All faculty members are requested to refer students with any of the above-mentioned conditions
to the Disability Support Committee for addressing disability-related accommodation
requirements.
Safe Space Pledge
This course may discuss a range of issues and events that might result in distress for some
students. Discussions in the course might also provoke strong emotional responses. To make sure
that all students collectively benefit from the course, and do not feel disturbed due to either the
content of the course or the conduct of the discussions. Therefore, it is incumbent upon all within
the classroom to pledge to maintain respect towards our peers. This does not mean that you need
to feel restrained about what you feel and what you want to say. Conversely, this is about
creating a safe space where everyone can speak and learn without inhibitions and fear. This
responsibility lies not only with students, but also with the instructor.
Plagiarism

The University rules regarding plagiarism will apply. Students are expected to be familiar with
and adhere to university policies in relation to plagiarism. A case of plagiarism will result in F
for the course.
Cell Phones

Not allowed

Laptops and Similar Gadgets

As needed
Part V

Reading Materials

For the list of relevant reading materials, see Relevant Readings provided in and at the end of
weekly course plan.

Course Design and Overview (Weekly Plan)

Week Topic and Reading Material

Description

1. MODULE1: COMPULSARY READINGS

 Leandro Tripodi, ‘Towards a New CISG: The Prospective Convention
INTRODUCTION
on the International Sale of Goods and Services’ (CUP 2015) 68
TO
 Wortley, B. A., ‘A Uniform Law on International Sales of Goods’
COMPARATIVE
(CUP 1958)
SALE OF
GOODS LAW
ADDITIONAL READINGS
This module  DiMatteo, Larry A, ‘International Sales Law : A Critical Analysis of
provides an CISG Jurisprudence’ (CUP 2005) 1
overview of
 DiMatteo, Larry A, ‘International Sales Law: A Critical Analysis of
international sale
CISG Jurisprudence’ (CUP 2005) 8
of goods law. In
 Matthias Herdegen, ‘Principles of International Economic Law’ (OUP
particular, it
2015) 351
discusses the
circumstances in
which a contract
becomes
‘international’.
How does one
differentiate
 between a
contract for the
sale of goods and
the sale of
services? What is
the relevance and
the need for
harmonization
and unification of
the law on the
subject? What are
the existing
Conventions and
when do they
apply? These are
some questions
that will be
discussed in this
module.

2-5 MODULE 2: THE COMPULSARY READINGS

INITIATION OF
DISPUTES AND THE
IDENTIFICATION OF  Alex Mills, ‘Party Autonomy in Private International Law’
THE APPLICABLE (CUP 2018) 390
LAW.
 Alex Mills, ‘Party Autonomy in Private International Law’
The chief question before
the adjudicator in (CUP 2018) 491
disputes on international  Hague Conference on Private International Law, ‘Principles
contracts – including
those for the sale of on Choice of Law in International Commercial Contract’
goods is the determining  J. H. C. Morris, ‘The Proper Law of a Contract: A Reply’, 3
whether it has
Int’l L.Q. 197 (1950)
jurisdiction to adjudicate
the dispute. If yes, what  John Collier, Contract Conflict of Laws (2001)
law will apply to decide
 Kadner Graziano, ‘Solving the Riddle of Conflicting Choice
the rights and liabilities
of the parties? This of Law Clauses in Battle of Forms Situations: The Hague
 module provides the Solution’ (2013)
answers to this question
 Official Journal of the European Union, ‘REGULATION
and familiarizes the
students with the (EC) No 593/2008 OF THE EUROPEAN PARLIAMENT
fundamental aspects of AND OF THE COUNCIL’ (17 June 2008) (Rome I)
understanding the
grounds on which a court  Official Journal of the European Union, ‘REGULATION
will assume jurisdiction (EU) No 1215/2012 OF THE EUROPEAN PARLIAMENT
and the law that will
govern the dispute. These AND OF THE COUNCIL’ (12 December 2012)
questions are  Saloni Khanderia, ‘International Approaches as Plausible
indispensable for
interested parties such as Solutions to Resolve the Battle of Forms under the Indian
litigants, lawyers and Law of Contract’ (Global Journal of Comparative Law 2019)
lawmakers. Lastly, this
 Saloni Khanderia, ‘The Hague Convention on Choice of
module will also discuss
the role, the significance Court Agreements and the enforcement of forum-selection
and the applicability of
clauses in Indian private international law’ (2019)
the CISG to international
disputes on the sale of
goods.

ADDITIONAL READINGS
 Henry Mather, Choice of Law for International Sales Issues
Not Resolved by the CISG, 20 J.L. & Com. 155 (2001).
 James T. Gilbert, Choice of Forum Clauses in International
and Interstate Contracts, 65 Ky. L.J. 1 (1976).
 Louis C. James, ‘Effects of the Autonomy of the Parties on
Conflict of Laws Contracts’ (1959)

5. MODULE 3: COMPULSARY READINGS

OVERRIDING
 MANDATORY RULES  Peter Kincaid, ‘Rationalising Contract Choice of Law Rules’,
Otago Law Review, (1993) Vol. 8 No.1, pg.93-124
AND PUBLIC POLICY.
In some situations, a  Peter Nygh, ‘Autonomy in International Contracts’, (Clarendon
court may be compelled Press- 1999) pg.105-121; 199-234; 235-257
to disregard the law that
would otherwise govern Saloni Khanderia, ‘Indian Private International Law vis-à-vis Party
the dispute to apply its Autonomy in the Choice of Law’, (2018) Oxford University
own law when foreign
law violates the public Commonwealth Law Journal, pg.1-16.
policy of the latter. The
public policy of the
forum is violated when
the application of foreign
law resulted in the
derogation of some
essential social concepts
of the forum. This
module discusses the
concept of overriding
mandatory provisions
and public policy and its
role in international
contracts for the sale of
goods.
6 - 7. MODULE 4: COMPULSARY READINGS

CONSEQUENCES OF
 Andrew Babiak, Defining Fundamental Breach under the
NON-
United Nations Convention on Contracts for the International
PERFORMANCE OF A
Sale of Goods, 6 Temp. Int’l & Comp. L.J.113 (1992).
CONTRACT.
 France Ferrari, Fundamental Breach of Contract under the
The parties’ inability to UN Sales Convention- 25 Years of Article CISG-, 25J.L. &
perform a contract may Com. 489 (2006).
be attributed to several  Ingeborg Schwenzer, Force Majeure and Hardship in
circumstances. In some International Sales Contracts, 39 VUWLR 709, 709- 726
(2008).
situations, it may be due
 Ingeborg Schwenzer, FORCE MAJEURE AND HARDSHIP
to an impeding
IN INTERNATIONAL SALES CONTRACTS
eventuality. In others,
 Saloni Khanderia, COMMERCIAL IMPRACTICABILITY
non-performance may
UNDER THE INDIAN LAW OF CONTRACT: THE
occur due to out of sheer
UNIDROIT PRINCIPLES AS THE WAY FORWARD
recklessness or the
 Sarah Jenkins, Exemption for Nonperformance: UCC, CISG,
inability to perform on a UNIDROIT Principles-A Comparative Assessment (1998)
timely basis. This module
discusses the nuances of
the non-performance of a ADDITIONAL READINGS
contract. In particular, it  Bridge, M, ‘Avoidance for Fundamental Breach of Contract
discusses the differences Under The UN Convention On The International Sale Of
between force majeure, Goods’ (CUP 2010)
frustration of contract,  Caslav Pejovic, CIVIL LAW AND COMMON LAW:
hardship and breach – TWO DIFFERENT PATHS LEADINGTO
these being the chief THE SAME GOAL
types of non-  DiMatteo, Larry A, ‘International Sales Law : A Critical
performance. What are Analysis of CISG Jurisprudence’ (CUP 2005) 151
the rights and liabilities  DiMatteo, Larry A, ‘International Sales Law : A Critical
of the parties when one Analysis of CISG Jurisprudence’ (CUP 2005) 132
party fails to perform?  DiMatteo, Larry A., ‘International Sales Law : A Global
The answer to this Challenge’ (CUP 2014) 237.
question depends on the  Grebler, Eduardo, ‘Fundamental Breach of Contract Under
law that will govern the the CISG: A Controversial Rule’ (CUP 2007)
dispute.
 Michael A. Schmitt; Bruce A. Wollschlager, Section 2-615
Commercial Impracticability: Making the Impracticable
Practicable, 81 Com. L.J. 9, 16 (1976)
 Michael Bridge, Avoidance for Fundamental Breach of
Contract under the UN Convention on the International Sale
of Goods, 59 Int'l & Comp. L.Q. 911 (2010)
 NDUBUISI AUGUSTINE NWAFOR, Comparative and
Critical Analysis of the Doctrine of
Exemption/Frustration/Force Majeure under the United
Nations Convention on the Contract for International Sale of
Goods, English Law and UNIDROIT Principles (2015)
 Ndubuisi Augustine Nwafor, The Comparative and Critical
Analysis of the Doctrine of Exemption/ Frustration/ Force
Majeure under the United Nations Convention on the
Contract for International Sale of Goods, English Law and
UNIDROIT Principles, A Thesis Submitted to the School of
Law, University of Stirling for the Degree of Doctor of
Philosophy (PhD) 1, 1-292 (2015).
 Thomas Black, Sales Contracts and Impracticability in a Changing
World, 13 St. Mary's L.J. 247, 290 (1981)
8. MODULE 5: PRODUCT  CALLIESS ROME REGULATIONS Commentary 443- 759 (2 nd
LIABILITY. Edition)
 John Ahern & William Binchy, ‘The Rome II Regulation on the
In some situations, the
Law Applicable to Non-Contractual Obligations, A New
use of a defective or
International Litigation Regime’
dangerous product can
result in injuries. This is  Reid Mortensen, Richard Garnett, Mary Keyes, ‘Private

known as ‘product International Law in Australia’, (3rd edn) pg. 17.1-17.53; 18.1-

liability’. To what extent 18.46

can an aggrieved party

claim damages for such ADDITIONAL READING
injuries?  Symeon C. Symeonides, ‘Choice of Law’, Chapter 9: Product
Liability, Oxford Scholarship Online (2016)

9. MODULE 6: THE LAW COMPULSARY READINGS

GOVERNING
LETTERS OF CREDIT  ICC Uniform Customs & Practice for Documentary Credits (UCP
IN THE 600)
INTERNATIONAL  Banking Regulation Act, 1949 [BRA] (India)
SALE OF GOODS 

10-11 MODULE 7: THE COMPULSARY READINGS

HARMONIZATION
AND UNIFICATION  Hague Convention on the Law applicable to Contracts for the
OF THE RULES ON International Sale of Goods (1986)
THE  Henry Deeb Gabriel, ‘Toward Universal Principles: The Use of
INTERNATIONAL Non-Binding Principles in International Commercial Law’, 17 Int'l
SALE OF GOODS. Trade & Bus. L. Rev. 241, 260 (2014)

This module discusses  Marco Torsello, ‘Reservations to International Uniform Law

the role of existing Conventions’, 5 Unif. L. Rev. n.s. 85, 120 (2000)

Conventions and other  UNIDROIT Principles of International Commercial Contracts

 international 2016
instruments in  United Nations Convention on Contracts for the International Sale
regulating the operation of Goods (2010)
of contracts for the  Wethmar-Lemmer The Vienna Sales Convention and Private
international sale of International Law (2010)

goods. In particular, it
discusses the provisions
of the United Nations
Convention for the
International Sale of
Goods (CISG). In what
circumstances does it
apply? To what extent
do its provisions
displace domestic law?
What is its relation to
other international
instruments in the field?
How are its provisions
interpreted in case of
ambiguity?

12 MODULE 8: THE COMPULSARY READINGS

ROLE OF SOFT
LAW
In the present era, soft
law instruments play an
important role in
 John Y Gotanda, Using the UNIDROIT Principles to Fill Gaps
harmonizing the rules in the CISG, Villanova University Charles Widger School of
pertaining to private Law 1, 1-26 (2007)
international  Michael Bridge, Avoidance for Fundamental Breach of
commercial law of Contract under the UN Convention on the International Sale of
contract. Moreover, Goods, 59 Int’l & Comp.L.Q.911 (2010).
provisions of these are  Saloni Khanderia, International Approaches as Plausible
often utilized by States Solutions to Resolve the Battle of Forms under the Indian Law
of Contract, 8 GJCL 1, 1-26 (2019).
as models to draft or
 Saloni Khanderia, The Hague Convention on Choice of Court
reform their own laws. Agreements and the enforcement of forum- selection clauses in
Alternatively, in the Indian private International Law, 9,No:3 Int. J. Private Law,
 recent past, there has 125, 125- 132 ( 2019)
also been an increasing  Sarah Howard Jenkins, Exemptions for Non-performance:
trend by courts to refer UCC, CISG, UNIDROIT Principles- A Comparative
Assessment, 72 Tul. L. Rev 2015 (1998)
to soft law instruments
such as Hague
Principles and/or the
UPICC whilst justifying
their decisions. This ADDITIONAL READINGS
module would thus
discuss the provisions  Caslav Pejovic, Civil Law And Common Law: Two Different
under the above- Paths Leading To The Same Goal, 32 VUWLR, 817, 817- 841
mentioned soft law (2001).
instruments.  J.H.C. Morris, The Property Law of a Contract: A Reply, 3.
Int’l L.Q. 197, 197-207 (1950).
 Louis C James, Effects of the Autonomy of the Parties on
Conflict of Laws Contracts, 36, Chicago- Kent Law Review,
34, 34- 59 (1959)
 Michael Joachim Bonell, International Investment Contracts
and General Contract Law: A Place for the UNIDROIT
Principles of International Commercial Contract, 17 Unif. L.
Rev. 141 (2012).
 Michael Whincop; Mary Keyes, Putting the Private Back into
Private International Law: Default Rules and the Proper Law
of the Contract, 21 Melb. U.L. Rev. 515 (1997).
 Ralf Michaels, The UNIDROIT principles as global
background law, 19 Unif. L. Rev 643, 643- 668 (2014)

13-14. MODULE 9: COMPULSARY READINGS

RECOGNITION AND
ENFORCEMENT OF  Hague Convention on the Recognition and Enforcement of Foreign
JUDGMENTS AND Judgments in Civil or Commercial Matters (2019)
AWARDS IN SALES  Saloni Khanderia, ‘The Hague Conference on Private
CONTRACT. International Law’s Proposed Draft Text on the Recognition and
Enforcement of Foreign Judgments: Should South Africa Endorse
A judgment or an award
it?’, Journal of African Law (2019) 63 (3), pg. 413-433
will be brutem fulmen if
it does not fulfil the  Saloni Khanderia, ‘The Hague Judgments Project: Assessing its

prerequisites of the law Plausible Benefits for the Development of the Indian Private

of the country where it International Law’, Commonwealth Law Bulletin (2018) 44 (3),

must be recognized. This pg. 452-475.

module discusses the

 circumstances for the
recognition and
enforcement of foreign
judgments and arbitral
awards in some major
jurisdictions.

15. MODULE 2: COMPULSARY READINGS

INCOTERMS

 ICC Guide to Incoterms 2010

 ICC Guide to Incoterms 2020: Introduction only
 INCO Docs, Global Trade Guide, Pages 3-5
Paul Deutsch, “‘Incoterms’ as an Instrument for the Allocation of
Risks in Foreign Trade.” Management International, vol. 5, no. 1,
1965, pp. 19–26. JSTOR,

15 READING AND Solving Past question papers

REVISION WEEK

Part V Treaties and Conventions covered

 Hague Convention on Choice of Court Agreements (2005)

 Hague Principles on Choice of Law in International Commercial Contracts (2015)
 International Chamber of Commerce INCOTERMS 2010
 Regulation (EC) on the Law Applicable to Contractual Obligations [Rome I] (2008) per
eur-lex.europa.eu
 Regulation (EU) no 1215/2012 on Jurisdiction and the Recognition and Enforcement of
Judgments in Civil and Commercial Matters (Brussels Ibis – recast) per
eurlex.europa.eu
 UNIDROIT Principles on International Commercial Contracts (2016)
 United Nations Convention on Contracts for the International Sale of Goods (Vienna
Sales Convention) (CISG).