「最重要牽連關係原則」為近年來所發展之重要理論，有別於傳統選法理 論之機械性。該原則強調應以與案件具有最重要關連地或國家之法律為其準據 法，以期達成判決公平，符合當事人期待，並實現具體妥當性之目標。
然亦因其具有彈性，故較無明確之選法標準，是其缺點。不過在涉外案件 日益增多及複雜之今天，各國對此原則之適用必會不斷地有新的立法例及實務 見解產生；相信透過不斷之探討，必能將此種抽象之概念闡明而形成共識。

Applicability of the most significant relationship rule in Conflict of Laws According to the Restatement of Conflict Laws, Second , U.S.A.
§6. Choice-of-Law Principles:⑴A court, subject to constitutional restrictions, will follow a statutory directive of its own state on choice of law. (2)When there is no such directive, the factors relevant to the choice of the applicable rule of law include:
(a) the needs of the interstate and international systems,
(b) the relevant policies of the forum,
(c) the relevant policies of other interested states and the relative interests of those states in the determination of the particular issue,
(d) the protection of justified expectations,
(e) the basic policies underlying the particular field of law,
(f) certainty, predictability and uniformity of result, and
(g) ease in the determination and application of the law to be applied.
And The General Principle of Torts §146 (1)The rights and liabilities of the parties with respect to an issue in tort are determined by the local law of the state which, with respect to that issue, has the most significant relationship to the occurrence and the parties under the principles stated in §6. (2)Contacts to be taken into account in applying the principles of §6 to determine the law applicable to an issue include :
(a) the place where the injury occurred,
(b) the place where the conduct causing the injury occurred,
(c) the domicil, residence, nationality, place of incorporation and place of business of the parties, and
(d) the place where the relationship, if any, between the parties is centered.
These contacts are to be evaluated according to their relative importance
with respect to the particular issue.
Also,§188. Law Governing in Absence of Effective Choice by the Parties (1)The rights and suties of the parties with respect an issue in contract are determined by the local law of the state which, with respect to that issue,
has the most significant relationship to the transaction and the parties under
the principles stated in §6. (2)In the absence of an effective choice of law by the parties (see §187), the contacts to be taken into account in applying the principles of §6 to determine the law applicable to an issue include:
(a) the place of contracting,
(b) the place of negotiation of the contract,
(c) the place of performance,
(d) the location of the subject matter of the contract, and
(e) the domicil, residence, nationality, place of incorporation and place
of business of the parties.
These contacts are to be evaluated according to their relative importance with respect to the particular issue.(3)If the place of negotiating the contract and the place of performance are in the same state, the local law of this state will usually be applied.