Actio Directa in International Jurisdiction and Applicable Law in Private International Law

The complex nature of the injured party’s right of direct action, as embracing insurance law and civil liability law, leads to a different characterization of such an action in the sector of jurisdiction, on the one hand, and that of applicable law in the realm of private international law on the other. That said, however, the solutions of private international law in both sectors are mutually dependent on each other, as can be seen from an analysis of the regime of the right of direct action in terms of both jurisdiction and applicable law.