Article 22 - States with More than One Legal System

Abstract

A. The notion of States comprising more than one legal system: I. Complex, as opposed to unitary, legal systems; II. The relevance of complex legal systems to the operation of the Rome I Regulation - B. The operation of the conflict-of-law provisions of the Regulation in the event of the designation of a complex legal system: I. The problem with the designation of complex legal systems and the solution envisaged by the Regulation; II. The rationale underlying the adopted solution ; III. Art. 22(1) as a guide to understanding references made to a State with more than one legal system for purposes other than the designation of the applicable law; IV. Issues, arising in respect of situations within the scope of application of the Regulation, to which Art. 22(1) does not apply - C. The non-application of the Regulation to purely local, as opposed to international, conflicts: I. The solution adopted by the Regulation and its raison d’être; II. The possibility for Member States to regulate local conflicts in conformity with the Rome I Regulation