Understanding of the Sitz Des Rechtsverhältnisses: Based on a Comparative Study of Other Theories of Private International Laws

Abstract

The current rapid theoretical development of private international law is inseparable from the foundation of the Sitz Des Rechtsverhältnisses laid by Savigny. Derived from the Roman law, the Sitz Des Rechtsverhältnisses and the most significant relationship rules put forward by Reece who critically inherited Savigny’s theory both reflect the consistent development of private international law. On this basis, referring to Geographical and Temporal Scope of Conflict of Laws and Legal Rules (Volume 8th of Modern Roman Laws) written by Savigny, this paper comparatively analyzes the similarities and differences between the Sitz Des Rechtsverhältnisses and the most significant relationship rules, so as to explore how the Sitz Des Rechtsverhältnisses impacts the contemporary legislation of conflict of laws in the world.