There is not a simple way. There have been many court cases over which is the correct jurisdiction and the court has come to the conclusion that the correct jurisdiction is “where the contract is substantially performed”. Putting it in another vague way, the court has also said, “applying the law with which it appears to have the closest and most substantial connection” which also doesn’t help much.
In determining this, the court would look at where the parties are based, where the contract was made and where it’s performed, the language of the contract and the styling of the wording, any stipulations which relate particularly to one jurisdiction or more but not another, the nature of the subject matter
The place of delivery is not necessarily the jurisdiction although it can be.
For example if a whole load of equipment was manufactured in England but simply delivered to Norway the contract would be substantially performed in England.
Many jurisdictions use English law because it is deemed to be probably the most measured and respected in the world.
Hence, you couldn’t necessarily say it was the English courts just because it was English law.
Can I clarify anything further for you?
Sometimes, there is no definitive answer to a question and it has to be decided by a court. This is one of those cases.
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