COMMERCIAL MARINE & PILING LTD v PIERSE CONTRACTING LTD
[2009] 2 Lloyd's Rep. 659
QUEEN’S BENCH DIVISION (TECHNOLOGY AND CONSTRUCTION COURT)
Before Mr Justice Ramsey
Conflict of laws — Jurisdiction — Guarantee — Irish company guaranteeing debt owed in England — Whether obligation in question to be performed in England — English law applicable to guarantee — Debtor required to seek out creditor — Rome Convention 1980, article 4.2 and 4.5 — Council Regulation EC (No) 44/2001, article 5.