The purpose of the present article is to illustrate how the method of characterisation could be used in Estonian private international law in order to achieve justice between the parties. It is not surprising that neither the Estonian Code of Civil Procedure ^*1 (hereinafter referred to as the ECC) nor the Private International Law Act ^*2 (hereinafter referred to as the PILA) contains any provisions addressing how the characterisation/classification ( kvalifitseerimine / karakteriseerimine ) should be done—this is a question that various jurisdictions have traditionally left to be decided by the case law and legal theory. ^*3