The common law rules have now been overlaid by statute.

This can include the court's own choice of law rules.

The court then applies the relevant choice of law rules.

There are differences between jurisdictions as to which choice of law rules should apply.

For each category, there is one or more choice of law rule(s).

The court will then apply the choice of law rules.

Where there are conflicting common law rules, the Act sometimes gives preference to one approach.

Where a case falls outside the section the common law rule will apply.

White examined the common law rule on this matter and its rationale.

The context in which the common law rule evolved was no longer valid.