The general principle of express trust conflicts law follows the doctrine of party autonomy, i.e., a trust is governed by the law chosen by the settler. Yet, where no applicable law has been chosen, both the (U.S.) Second Restatement of Conflict of laws and the Hague Trusts Convention adopted the so-called "the most significant relationship (the most closely connected) test". The author of this article is of the opinion that any attempt to resolve conflicts problems by means of a set of fixed rules that fail to take into account the substantive tenor of a specific legal pattern is bound to disappoint. Furthermore, the most important influencing consideration to trusts, internal or foreign, is the justified expectation of the settler, which obviously being the prevailing value of express trusts. It is along this line of thought that the "Prevailing Value Based Approach" to trusts conflicts law is for now proposed for the purpose of individual justice as well as certainty/predictability, both being the goals of Conflict of Laws.