The Blue Sky Case and the Cape Town Convention
DAVID MAUGHAN on the crucial difference between Irish and English law in regard to aircraft mortgages: 'The international interest created under an Irish law aircraft mortgage will exist under the laws of Ireland even where such Irish law aircraft mortgage is not considered effective security under the laws of the place where the aircraft is located at the time the Irish law aircraft mortgage is executed.' By contrast, he says, 'it seems that the English courts will only treat an English law aircraft mortgage as creating a valid security interest if, when the English law aircraft mortgage is executed, the aircraft is located either in England or in another jurisdiction which will give legal effect to an English law aircraft mortgage.'