[2006] 1 WLR 1792

David Allen – Conflict of laws – Tort – Choice of law – Foreign tort claims – Asbestos-related tort claims brought against companies in United Kingdom and United States – Relevant acts or omissions committed in United States before commencement date of statute governing choice of law – Resulting damage occurring after commencement date of statute – Whether choice of law to be determined by common law rules or under statute – Private International Law (Miscellaneous Provisions) Act 1995 (c 42), s. 14(1)