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Judicial clarification of the choice of law rules for aircraft mortgages: how a mortgage may be effective in one jurisdiction but ineffective in another

  • Norton Rose LLP
  • -
  • United Kingdom
  • -
  • April 14 2010

The English High Court has recently held that: it is the lex situs (that is, the laws of the jurisdiction where the relevant asset is situated at the time that the interest is created) which determines whether a property interest, such as a mortgage, is effectively created over that asset