Abstract

This paper is based on reform recommendations contained in a 2009 report by the Manitoba Law Reform Commission into the rules of private international law. The reform recommendations relate to (a) whether a flexible exception should be applied in relation to the application of the law of the place of the wrong in torts cases; (b) whether the rules regarding the classification of limitation periods as either substantive or procedural should be codified; and (c) that the rules in relation to the exercise of jurisdiction contained in the Uniform Law Conference of Canada be adopted. In critiquing the Commission’s proposals, the law in these areas in other jurisdictions, including the United States, Europe (including the United Kingdom), and Australia are considered and compared.

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