The place of the contract governs the act.

Explanation

(English-origin maxim.) The law of the place where the contract was made governs its validity and interpretation — the parties are presumed to have contracted with reference to the law of that place.

Where this applies

• Two parties sign a contract in France, and a court determines the contract's validity under French law because the place of the contract governs.
• A loan agreement executed in New York is interpreted according to New York law, even though the borrower has since moved to Texas.
• A handshake deal made at a cattle auction in Montana is governed by Montana law because that is where the contract was formed.