Negotiable Instruments

A cheque travels. A Dubai buyer of Indian spices signs a cheque in Dubai, hands it to an agent, the agent endorses it in Mumbai, and it is deposited at a bank in Singapore where it bounces. Several people have now put their names on one piece of paper in three countries. If the holder sues, does one country's law decide what each signatory owes, or does each signature have its own law? The Negotiable Instruments Act answers this in a short chapter headed International Law, and the answer is a good lesson in how conflict rules work.

In two minutes

Each person's liability on a negotiable instrument is a separate contract with its own governing law: for a foreign instrument, the maker or drawer by the law of the place where the instrument was made, acceptor and indorser by the law of the place of payment, unless the contract says otherwise (Negotiable Instruments Act 1881, s.134).

The rest of this chapter

The full explanation, the cheat sheet, every previous-year question at every mark weight, the quiz and the answer skeletons are part of Conflict of Laws on LexBlox Semester. Sign in to unlock the subject, or read Module 1 of Legal Language and Writing free.