international practice

The notion of a law of obligations goes back to Roman law where it was a category that consisted of personal actions (actiones in personam) which could be brought by one person against another named person. In Roman law, obligations was a sub-category of the law of things, ‘things’ (res) in this respect being construed widely to include not only physical things, but intangible forms of property embracing even obligations, or legal duties, to act and to refrain from acting. The other sub-category in
the law of things was, to use a modern category, the law of property and this comprised of actions originally seen as being available against things (actiones in rem).
international commercial litigation

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