APPLICABLE LAW ON QUASI-CONTRACTS IN THE CONFLICT OF LAWS

Quasi- Contracts such as undue payment, negotiorum gestio and enrichment constitute one part of connection group of Extra Contractual Obligations in conflict of laws where source of obligation is a voluntary profitable act. The growing importance of this branch of is due to expansion of international communications and determining the proper law for this connection group is possible by legally analyzing nature and basis of each obligation. Unlike contractual obligations, these obligations are imposed by law, but their nature is different from delictual obligations so that they are derived from a voluntary profitable act which makes that party obtain unjust benefit at the other party's expense. So it is necessary to ascertain a proper law which has closest and most substantial connection with the connecting factor.