Shareholder Meetings: Comparison Between Thai Law And American Law



This paper addresses a need for legal predictability in international sale of goods. The author explores the twin purposes of the CISG to provide uniform substantive rules for international sale contracts and to solve conflict of laws problems through a uniform choice of law principle. The paper explores the regime of conflict of law rules in the CISG in comparison with the Hague Convention on the Law Applicable to the Contracts for the International Sale of Goods, EC Rome Convention on the Law Applicable to Contractual Obligations, and the Inter-American Convention on the Law Applicable to International Contracts. The scope of the CISG is limited to formation of the contract and the rights of buyers and sellers. The paper concludes by pointing out this limited scope of CISG and advocating a convention that provides uniform set of rules for conflict of laws for all issues that may arise in international sale of goods. This convention would be a one-stop shop for all conflict of laws issues relating to the formation, execution and termination of international contracts for sale of goods.