The aim of the Hague Conference on Private International Law is to work towards international unification of the rules in this area. Its hundred years of activity, and particularly the past forty years, have been devoted to producing conventions unifying the rules of law in the three central issues of private international law: jurisdiction, choice-of-law, and the enforcement and recognition of foreign judgments. These three distinct issues correspond to three distinct stages of litigation. The rules of jurisdiction answer the question, which state's courts have jurisdiction to decide a case or, from the perspective of any given state: does its courts have jurisdiction over the case? Choice-of-law rules, in contrast, answer the question, which law should govern the case, irrespective of where it is being adjudicated? Finally, the rules relating to foreign judgments define the terms on which a decision given in one state will be recognised and enforced in another.
Private International Law in Africa: The Past, Present, and Future*