Abstract

Through this article, the author purports to draw a detailed comparison of European and American revolution, along with India's position in the conflict of laws. The Indian Private International law has been long viewed as a model strongly influenced by the English system of Conflict of Laws, which the author of this paper believes should undergo a revolution of its own in order to suit the quasi-federal system of this nation. The past few years have observed a drift from the English Private International law, such as the evolution of the choice of jurisdiction of courts vested in the hands of the parties to disputes. While the private international law in the Western Nations deal more with the conflicts between the territorial laws, the conflicts in India are mainly based on personal laws. This paper purports to establish the revolutionary changes that were brought about by the US and the European in their own ways to the Conflicts law regime. Secondly, it draws a difference between the two conflicts revolution and how they respectively impacted the Conflict regime. Thirdly, through the two revolutions, this paper shall aim to establish whether Indian revolution should rely on one of the two methods of revolution as adopted by US or Europe, or whether India should fall back on a third method of revolution.

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