On Unilateralism in Choice of Law

Unilateralism and multilateralism are two approaches in choice of law that are contradictory and uniform at the same time.Unilateralism existed during the statutist period in conflict of laws,but it was neglected and replaced by multilateralism during the time from the middle of the 19th century to the beginning of the 20th century when the statutist theory was overturned and the vested right theory as well as the theory of the seat of legal relationship prevailed.As the state strengthened its role in foreign commercial relationships,unilateralism revived both in European and American private international law.So it is significant to the legislation in People's Republic of China to reevaluate unilateralism and make use of the legislative and judicatory experiences in Europe and the U.S.