The law of the place where the contract was made. Lex Domicilii: The law of the person's permanent home.
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Under the principle of , nations generally respect the judicial acts of others, provided the original court had proper jurisdiction and the proceedings were fair (not contrary to "public policy"). Without this mutual recognition, international trade would be paralyzed by legal uncertainty. The Core Tension: Sovereignty vs. Justice The law of the place where the contract was made