A Comparative Study of the Law Governing the Civil Liability in Iranian and English Law from the Conflict of Law's Perspective

Compensation for losses caused by the adverse events is one of the important issues in private international law. Many countries have specific regulations on this issue and clarify the civil liability issues. Taking a quick look at the related regulations shows that many of these countries have followed English law. Similarity rule was being applied in England for many years, but by enacting the rules of private international law, the mentioned rule was replaced by lex loci delicti commissi – the law of the place where the tort was committed-. There is no specific law for determining the law governing civil liability in Iran. Therefore, like what is done in English law, Iranian legislators can rely on lex loci delicti commissi and enforce the appropriate law in exceptional cases.