摘要：After the entry into force of the Estonian Law of Obligations Act*2 (LOA) in 2002, Estonian courts havebeen faced with the need to distinguish among various contractual and non-contractual obligations, ofwhich some, such as the non-contractual obligation related to the public promise to pay (LOA, §1009) or theobligation to present a thing (LOA, §1014), were previously not even known in Estonian substantive law ofobligations. Although the distinctions among various obligations in Estonian substantive law have becomeclearer and clearer as the case law has evolved, it is still unclear how the Estonian notions of contractualand non-contractual obligations should fi t within the framework of the private international law instrumentsapplicable in the Estonian courts.*3 So far, the characterisation of contractual and non-contractualobligations has attracted undeservedly little attention in Estonian literature on private international law*4,although such disputes are at the heart of international trade and commerce.
