The Brexiteers won in the 2016 EU referendum. In order to formally leave the European Union, the UK government experienced considerable political wrestling with the Parliament. In addition, the Brexit process was repeatedly extended by the negotiation between the British government and the European Union. The UK officially left the European Union on 31 December 2020. Apart from the procedures stipulated in Article 50 of the Lisbon Treaty and the guidelines provided by the EU, the EU and the UK government shall sign the Withdrawal Treaty to complete the Brexit process.
Brexit is not an end, however, but another beginning. After Brexit, the United Kingdom is no longer a member of the EU framework. Therefore, the United Kingdom should re-conclude international treaties with all countries, including the European Union, to deal with issues such as trade and judicial cooperation, not to mention the conflict of laws. With the content of conflict of laws being too broad, this article only discusses the choice-of-law rules of contractual and non-contractual obligations. Along with an assessment of the background of Brexit and Article 50 of Lisbon Treaty, the evolution of the British conflict of laws norms is the central theme of the present work. To that extent, this article only dissertates the difference of the contractual obligations and the non-contractual obligations before and after Brexit. Firstly, this article will explain how to resolve conflict of laws issues before joining the European Union (and its predecessor).How to apply conflict of laws norms after joining it will then be examined, followed by a survey of the relevant issues after leaving the European Union. In conclusion, an analysis of the future trend of British conflict of laws norms is also presented.
