Private International Law, Art and Cultural Heritage, Christa Roodt

Abstract

This book constitutes a fascinating account of the relationship between private international law and cultural heritage law. The author argues in favour of a value-based approach to private international law in this regard (both in respect of jurisdiction and applicable law), inspired by the ethical standards that underlie cultural heritage law (see eg 340). In the course of the argument, interesting remarks are made about choice of law methodology in general, for instance, that the ‘divergence between multilateral and unilateral conflicts rules in private international law is a matter of degree rather than a strict dichotomy’ (88; also see 106).