When it comes to the common law rules of private international law, the jurisdictions of the common law are a little like those of the Anglican Communion: in places far from London, and where library resources are probably rather patchy, the endeavour is made to remain faithful to a system which the mother country has treated in a rather cavalier way. The rules of private international law in England have been allowed to grow so complex that, if they ever truly realised what has happened, those who cleave to an earlier, simpler, truer, form of the doctrine would be appalled. Reading Professor Oppong's clear, accessible, informed and informative survey of the private international laws of the common law and semi-common law (which is really to say, systems which combine some common law with the Roman-Dutch tradition) jurisdictions of the African mainland, almost everything is recognisable. Of course, the reference in the title to the Commonwealth must be taken cum grano salis: the laws of Zimbabwe, which has been cast out, and Gambia, whose President recently denounced its membership, are included; and Cameroon, Mozambique and Rwanda, which have more recently been admitted, are not referred to. But one is instantly and repeatedly struck by the echoes of an earlier, simpler, common law, uncomplicated and unbent by large-scale international commerce or by Europe. It would not be altogether accurate to describe the material assembled and analysed as “the common law plus RSC Order 11 as it was at the date of national independence”, for more recent principles such as forum non conveniens appear to have gained a toehold in some national systems, and most of the States studied have acceded to the 1958 New York Convention. But, when one sees the shortness of the chapter on choice of law in tort, it serves to remind the reader, at least if he is of a certain age, of how rudimentary the private international law of tort used to be.

Professor Oppong has mined the available resources in and for a dozen countries. His methodology, at least so far as concerns the presentation of his work, is to take familiar chapter headings, to say what he has found under them for each country in turn, and then to provide some mild (though he is unimpressed by those States which have preserved the rule that a wife has the domicile of her husband foisted upon her) and balanced comments. Of course the overarching comment, that, while in very many respects the common law rules of private international law are assumed to be in force, there is no local authority to vouch for this proposition, need be made only once, even if it is by far the largest point. The impression is that the subject is alive and subject to daily scrutiny only in Nigeria and South Africa, but that, if South Africa were removed from the book, there would not be a lot left. That said, his account of South African law on the establishment of jurisdiction by attachment is quite the clearest and most accessible available in England; and it does give the reader the opportunity to reflect on the sense of a rule that may be explained as meaning that, if a person chooses to leave property within the jurisdiction of a court, it is not unprincipled that he be taken to have accepted the jurisdiction of the courts of that place, at least up to the value of the local property