In choice-of-law decisions, there is but one basic policy, namely, protection of the expectations of the parties. Such predictability is served, and party expectations are protected, by giving effect to the parties' own choice of the applicable law. Party autonomy means that the parties are free to decide the law governing their contract, subject to certain limitations. This principle is articulated in paragraph 1, article 6 of ROC's Law governing the application of laws to civil matters involving foreign elements which provides: "The applicable law of obligations based on legal deed shall be decided by the principle of party autonomy. " However this article is not identical with the principle of party autonomy in that the latter limits her application only to contractual obligations whereas the former includes not only contractual obligations but also obligations based on unilateral deeds. Since this article is numerously invoked in court decisions on international trade and maritime issues, a study to correctly apply this article is worthwhile in view of the fact the supreme court of ROC interprets this article in a sharp contrast to those of both civil law and common law countries and scholars. In this connection, art. 3 of the Rome Convention on the Law Applicable to Contractual Obligations (in force among the European Community Countries 1991) permits the parties to select the applicable law. The choice must be express or must appear with sufficient certainty from the circumstances. The Restatement concludes when the parties have not made a choice, either expressly or by implication, the principal choice-of-law refers to the place of the "most significant relationship" which includes many of the same factors, including party expectations, as would a hypothetical party intent. For the part of English law, the concept of Proper Law is the main idea. As opposed to the foregoing, the supreme court of ROC maintains that the parties can do so only by means of an express choice-of-law clause in their written contract. Taking Civil Adjudication of Thwei-kao Fa-yuan, 1992 Tai-sang 935 for example, the supreme court, irrespective of the express choice-of-law clause written in bill of lading, jumps the conclusion that since the issuance of bill of lading is legally an unilateral deed rather than a written contract, paragraph 1, article 6 of ROC's Law governing the application of laws to civil matters involving foreign elements is, therefore, not applicable. Obviously, the article is narrowly applied regardless of civil law and common law country interpretations on this issue. This interpretation significantly and substantially affects the international trade and maritime decisions. In view of the fact that we relies heavily on international trade, we shall reevaluate this issue so as to facilitate and promote the international trade.