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Under the common law as applicable in Nigeria, parties to a contract are free to determine the law that will govern their contractual obligations. Such choice must be bona fide and legal and there must not be any reason to avoid the choice on the ground of public policy. Even where the seller and the debtor are resident within Nigeria and the transaction that gives rise to the receivables and the payment of the receivables takes place in Nigeria, the foregoing principle will apply. However, the mandatory provisions of Nigerian law would continue to apply to the contract.

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