The validity of a cheque; the requirements relating to the drawing and form, the negotiation, the presentation and payment; and the recourse for non-payment, are all governed by national law. Conflicting national laws may lead to different results as to the rights and obligations of the parties concerned in the event of a dispute relating to a bill or a note which has connections with more than one country. This adds a degree of uncertainty to international commercial transactions and may result in a grave injustice for one or more of the parties concerned.