A Jurisprudence Review of the Doctrine of the Most Significant Relationship

As a new system in international private law, the doctrine of the most significant relationship results from the political economic cultural and philosophical base. The paper gives an analysis of the origin of the doctrine of the most significant relationship as well as the use in different countries, and makes a contrast between continental law system and Anglo-American law system in the limitation of discretion, and points out that the scope and boundary of the doctrine of the most significant relationship should be properly understood.