Abstract
The most significant connection doctrine plays important role in the conflict of laws. It has been applied not only in the field of contracts but also to several particular issues in areas other than contract. Courts in different jurisdictions
have often adopted the notion of characteristic performance and provide some presumptions to determine the country of most significant connection. In default, the court has to impute an intention by asking, as just and reasonable persons, which laws of the parties ought to, or would, have intended to nominate if they had thought about it when they were making the contract. In the absence of express or implied agreements, the proper law of the contract will be determined to be the system of private law which the transaction has the closest or most real
connection. This is an objective test to be determined by the circumstances of the case. This paper will examine briefly some select choice of law rules as well as the factors that a court will consider in determining the law with the most significant connection as well as its application in the Nigerian legal system and
the United Kingdom.
Keywords: International Law, Jurisdiction, Conflicts Resolution.