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Abstract

A civil wrong having been committed on board a vessel in foreign territorial waters, the tort by hypothesis being maritime and the court having jurisdiction, the problem then arises as to what law governs the disposition of the case. Stated more specifically, does the nature of admiralty jurisdiction demand that a court, in determining liability for civil wrongs committed in foreign territorial waters, should ignore or modify well-settled principles of the conflict of laws as applied to delictual obligations? This is the point of departure for the discussion to follow.

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