Conflict of laws is well-served by books. Dicey and Morris is that rare phenomenon, a leading practitioner treatise which is at the same time regarded as a leading academic text. Cheshire and North is an excellent student text from which practitioners may also profit. Morris is a student reduction of the monumental practitioners’ text. So, when two new books appear virtually simultaneously, the question must be asked: first, to whom are they addressed? and, secondly, what, if anything, do they have to offer which is new? Are there new theories or novel insights? Do they look at the subject differently? Is there a different management of subject-matter or a new emphasis? Is their style noticeably different from the existing books? The books under review adopt conventional approaches to the subject: for example, the emphasis in both is on choice of law rules, not jurisdiction.

My first reaction to both books, then, was one of scepticism. Was there really a gap in the market that either, or both, could fill? I bore in mind that conflict of laws is a specialist subject and that, although interest in it is expanding with increased personal mobility and the intensity of international business transactions, there were only so many potential readers. Having used both books, much of this scepticism has gone. The value of both books lies in their brevity. Both are shorter than the next largest competitor (Morris) and both are very short in comparison with the latest Cheshire and North, which runs to 922 pages. Both are also fairly comprehensive. Collier covers all the main topics except trusts (despite the new legislation), bankruptcy, the winding-up of companies, the exercise of powers of appointment, and the enforcement of maintenance orders (all omitted on the ground that they tend to be left out of academic courses). Jaffey’s omissions are broadly the same but also include sovereign immunity (arguably the subject of public international law and/or constitutional law anyway) and negotiable instruments (to which Collier gives cursory treatment).

Both books are also admirably comprehensible. Both write in a clear, intelligible, lucid way. Given space limitations, Collier is stronger than Jaffey on historical development and on policy issues. His text is also the more stylish and idiosyncratic, with footnotes in particular spiced with wit and some bite (though they are occasionally silly). Both authors write (necessarily) in an economical style but rarely does either fail to communicate the point he is making. This is truly remarkable given the complexity of the ideas involved.

Perhaps it is because of that very complexity that both authors are at their weakest in presenting the law on jurisdiction. Jaffey synthesizes the common law and Brussels Convention rules into one chapter. Though he does this carefully, the student new to the subject may not find this approach enables him to grasp the essential differences or details of the two structures. Collier devotes rather more space but tends not to be at his most fluent here. The reference to a defendant’s being “domiciled in a Member State of the EEC”, the sort of casual expression we all make in tutorials, is misleading. It should read “domiciled in a Con-