Red Sea Insurance Co Ltd v Bouygues SA [1995] 1 AC 190 is a judicial decision of the Privy Council relating to choice of law in tort.

[1] The case was an appeal from the decision of the Court of Appeal of Hong Kong, but as the case was decided in Hong Kong pursuant to the English Law Ordinance, section 3(1),[2] it is also taken to be an authoritative statement of English law.

In its counterclaim Red Sea Insurance alleged that one of the co-plaintiffs, PCG, negligently supplied faulty pre-cast concrete building units, and that if it was liable at all, Red Sea Insurance would be subrogated to the claims of the other co-plaintiffs against PCG.

After reviewing the relevant authorities Lord Slynn held that the "flexible exception" to the double actionability requirement which had been created by the House of Lords in Boys v Chaplin [1971] AC 356 could apply in favour of not only the forum (the lex fori) but also in favour of the law of the place where the tort occurred (the lex loci delicti commissi).

[3] In England the decision was followed by the Court of Appeal in Pearce v Ove Arup Partnership Ltd [2000] Ch 403, it has now largely been superseded by the Private International Law (Miscellaneous Provisions) Act 1995.