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hl=en_US In a particular case, the United States will generally consult closely with the organization involved, and take vigorous action, as appropriate, to ensure that the matter is properly presented to its courts. The means for domestic implementation of an obligation, however, are not an excuse for failure to implement the obligation. Whatever domestic means are chosen, each country remains obligated to reach the correct result and to grant immunity as required by the General Convention. The United States thus recognizes that any failure by its courts to accord immunity where it is due under the Convention would be a breach of the Convention.
"most significant connection" - The principle of the conflict of laws according to which the "proper" (i.e. applicable) law of a contract or tort is the law which, on policy grounds, appears to have the most significant connection with the chain of acts and consequences in the particular case at hand. This connection is assessed by consideration of the "connecting factors," or "contacts" (supra), linking the legal situation concerned with the different jurisdictions involved. The term was used by J.H.C. Morris in his renowned essays, "Torts in the Conflict of Laws" (1949) 12 Modern Law Rev. 248 and "The Proper Law of a Tort" (1951) 64 Harv. L. Rev. 881. In contract conflicts, the corresponding term generally used in the United Kingdom and British Commonwealth countries today is "closest and most real connection". See, e.g., Dicey and Morris, The Conflict of Laws, 11 Ed., 1987 at Rule 180. In tort, the term "most significant relationship" (infra) has the same meaning. See, e.g., Dicey and Morris, ibid. 12 Ed., 1993 at Rule 202; Morris, Conflict of Laws, 2000; see Westlake (infra); Tetley, Int'l. C. of L., 1994 at pp. 10-12, 13, 27, 42, 438. Mareva Injunction - The injunction was first granted by Lord Denning M.R. in 1975 in Nippon Yusen Kaisha v. Karageorgis [1975] 2 Lloyd's Rep. 137 (C.A.), and the name "Mareva" derives from Lord Denning's second decision issuing such an injunction, in Mareva Cia. Naviera S.A. v. International Bulkcarriers (The Mareva) [1975] 2 Lloyd's Rep. 509 (C.A.). In the United Kingdom, the Mareva injunction is now provided for by legislation, at sect. 37(3) of the Supreme Court Act 1981 (U.K. 1981 c. 54). See Tetley, M.L.C., 2 Ed., 1998 at pp. 987-997, 1001-1006; Tetley, Int'l. M. & A. L., 2003 at pp. 409-411. Dadourian Group International Inc. v. Simm [2006] 3 All E.R. 48 (C.A.). Mareva injunction does not exist in the United States. See Grupo Mexicano de Desarollo v. Alliance Bond Fund, Inc. 527 U.S. 308, 1999 AMC 1963 (U.S. Supr. Ct. 1999). For the existence of the Mareva injunction in Canada see Aetna Financial Services Ltd. v. Feigelman [1985] 1 S.C.R. 2. The legal principle thus expressed is that, on grounds of public policy, no court will lend its aid to a party who founds his cause of action on an illegal or an immoral act. See SCB v. PNSC [2000] 1 Lloyd's Rep. 218 at p. 231 (C.A.), citing Lord Mansfield in Holman v. Johnson (1775) 1 Cowp. 341 at p. 343, 98 E.R. 1120 at p. 1121. For an application of the principle, see Clunis v. Camden and Islington Health Authority [1998] 2 W.L.R. 902 at p. 908 (C.A.):