The law of the place in which a delict (tort) is committed. In private international law as applied in most countries in Europe, this law governs liability for torts. In some cases, however, it may be difficult to establish where the tort was committed (for example, when goods negligently manufactured in one country are distributed in another) or the place may be a matter of mere chance (for example, when an aeroplane crashes and lands). For these reasons, England does not accept the theory that liability in tort is governed by the lex loci delicti. Case: Monro v American Cyanamid Corporation  KB 432.