Comparative conflict of laws : conventions, regulations, and codes
著者
書誌事項
Comparative conflict of laws : conventions, regulations, and codes
Thomson Reuters/Foundation Press, 2009
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収録内容
- United States private international law codifications
- Conflicts law in the European Union
- Hague conference on private international law conventions
- Private international law codifications of selected European nations
- Private international law codifications of selected other nations
内容説明・目次
内容説明
This regulations and codes title is designed to assist conflict of laws teachers in taking a comparative approach to the subject. International commercial transaction have become commonplace. Many injuries and deaths have their causes or their victims abroad. It is therefore imperative that the course in conflict of law include study of how foreign countries treat the course's major topics of judicial jurisdiction, choice of law, and recognition and enforcement of judgments. Interesting patterns emerge. Many choice-of-law codes and regulations have, as an exception to applying the law of the place of injury to torts, the law of the common domicile of the parties. In family-law related matters, there is much adherence to citizenship as a party's "personal law."domicile of the parties. Many examples could be given of the need for a comparative approach to conflict of laws. These materials, treaties, regulations, and codes from around the world, with questions and comments, will
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