‘Towards the Attainment of Complete Uniformity’ in Private International Law

This article uncovers a convention on foreign judgments, negotiated between Britain and Italy in 1887. The Prime Minister, Lord Salisbury, saw it as ‘the most practical first step towards the attainment of complete uniformity’: proof that the civil and common law worlds could agree on common private international law rules. It was Britain’s first such agreement with a civil law country, half a century before much narrower agreements with France and Belgium. It remained unratified amid Italian political instability and perceived German influence (similar concerns scuppered negotiations in the 1930s). The convention was the high-water mark of British attempts to take a leading role in pan-European codification. By the 1890s, under Dicey’s influence, Britain had abandoned its grand ambitions for a truly global regime. The common law was left to its own devices for another generation, with Britain standing aloof from the codification projects it had once sought to lead

Commission · Convention · Foreign policy · International relations · Conflict of Laws and Jurisdiction · European and International Contract Law · International Law and Aviation