The Private International Law (Miscellaneous Provisions) Act 1995, Part III1 makes radical changes to the choice of law rules for tort claims litigated before English courts. The common law rules, as enunciated in Phillips v. Eyre,2 required a plaintiff to show that the conduct complained of (i) was such as would have given rise to liability in tort in domestic English law,3 and (ii) was actionable under the civil law of the country in which it occurred. According to Boys v. Chaplin 4 and Red Sea Insurance Co. Ltd. v. Bouygues,5 this general rule could be departed from in an appropriate case, so that a particular issue, or even the entire question of liability under one or other limb of the general rule, might be governed by a different law with which the particular issue was more closely connected. Thus a plaintiff could still recover even though the law of the place of the tort would disallow some6 or all7 of his claim. Likewise, he could still recover in respect of a tort actionable under the law of the place where it occurred, even though the conduct would not have been actionable as a tort had it occurred in England.8 Exceptions apart, however, a defendant to a tort claim could not be made liable in an English court for conduct which would not have amounted to a tort, or for damages of a type which would not have been recoverable in tort, under domestic English law.