Choice of law refers to what jurisdiction’s law is to be applied in the matter. Choice of law refers to the area of law, in which, the court determines whether to apply the forum state law or apply the law applicable in another jurisdiction which has an interest in the controversy. Courts faced with a choice of law issue generally choose between the laws of the state where the lawsuit was brought and laws of the state where the cause of action arose.
The three basic types of approaches to choice of law are the traditional vested rights doctrine, various interests and analysis approach and most significant relationship theory. The “most significant relationship” theory of the Second Restatement attempts to determine which state has the “most significant relationship” to the case. To determine whether a more significant relationship exist, various aspects like, place of injury, place of the conduct causing injury, residence or place of business of the parties, and the place where any relationship between the parties is centered is taken into consideration.