Mr. Kgosi represents Light Solutions 1246/1993 (Pty) Ltd, of which he is the sole director and shareholder. Although the company was formed and registered in the People's Republic of China, it is registered as an external company in South Africa and its primary place of business is registered at the Companies and Intellectual Property Commission as 251 Lunnon Road, Hatfield, Pretoria. Mr. Kgosi sold 100 000 solar panels 'CIF Durban' to Mr. Ramasa. The contract was concluded in England during a conference. The contract contains a clause that the solar panels must be SABS compliant. Mr. Kgosi arranged for 100 000 identical and unmarked solar panels to be transported on a truck from his business premises in Dubai to the Dubai harbour. On arrival of the truck at the Dubai harbour, 100 000 solar panels were offloaded and delivered to the control of the international carrier for shipment to Durban. At the time of shipment, the 100 000 solar panels were not yet certified as SABS approved. By the time the consignment of solar panels reached Durban, they were declared nonSABS compliant. This was due to no fault on the part of either the seller or buyer or any of their agents.

Provide the proper law applicable to the transaction, and the body of law applicable to the formalities relating to the contract. Make reference to the principles of South African international private law.