Conflict Of Laws A Comparative Approach

Author : Cuniberti, Gilles
Publisher : Edward Elgar Publishing
ISBN 13 : 1839106530
Total Pages : 488 pages
Book Rating : 4.38/5 ( download)

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Download or read book Conflict of Laws: A Comparative Approach written by Cuniberti, Gilles and published by Edward Elgar Publishing. This book was released on 2022-02-18 with total page 488 pages. Available in PDF, EPUB and Kindle. Book excerpt: Now in its second edition, and with significant updates and new material, Gilles Cuniberti’s innovative textbook offers a comparative treatment of private international law, a field of great importance in an increasingly globalized world. Written by a leading voice in the field, and using a text and cases approach, this text systematically presents and compares civil law and common law approaches to issues primarily within the United Kingdom, United States, France and the EU, as well as offering additional updated insights into rules applicable in other jurisdictions such as Japan, China and Germany.

Author : Frank Bates (LL. M.)
Publisher :
ISBN 13 : 9780409340280
Total Pages : pages
Book Rating : 4.86/5 ( download)

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Download or read book Conflict of Laws As Taxonomy written by Frank Bates (LL. M.) and published by . This book was released on 2015-06-23 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: Conflict of Laws as Taxonomy: A New Approachoffers a unique analytical and doctrinal approach to the conflict of laws. Its purpose is to review and assess the traditionally accepted methodology and taxonomy used in the resolution of cross-jurisdictional matters and to suggest alternative ways in which such matters may be classified, with resulting practical application to the conduct of cross-border disputes. Format: Paperback The author of this text provides a fresh comparative approach towards key issues, as well as examining the various theories that have been devised to explain the ways in which different approaches have been justified. This comparative discussion highlights the strengths and weaknesses of particular jurisdictionsoÂeÂ(tm) treatment of the conflict of laws and uses this to develop an understanding of these differences. This is essential knowledge in preparing for the jurisprudential approach likely to be applied in those jurisdictions in overseas practice and litigation. Of particular relevance is the consideration of the divergence between courts in the United Kingdom (because of its membership of the EU), the United States (which has, for nearly 200 years pursued a more jurisprudential approach) and Australia. In the current environment of increasing globalisation, the book will be of great benefit to practitioners and litigators involved in cross-jurisdictional matters, while its scholarly and authoritative analysis will engage and inform researchers and students of conflict of laws, comparative law and jurisprudence. Features oÂeo Unique analytical and doctrinal approach to conflict of laws oÂeo Detailed comparative examination of the approaches across UK, US and Australian jurisdictions oÂeo Extensive review of case law Related LexisNexis Titles Davies, Bell & Brereton, NyghoÂeÂ(tm)s Conflict of Laws in Australia, 9th edition, 2014 Mortensen, Garnett & Keyes, Private International Law in Australia, 3rd edition, 2015

Author : Nikitas Hatzimihail
Publisher : Cambridge University Press
ISBN 13 : 0521863023
Total Pages : 643 pages
Book Rating : 4.25/5 ( download)

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Download or read book Preclassical Conflict of Laws written by Nikitas Hatzimihail and published by Cambridge University Press. This book was released on 2021-07-22 with total page 643 pages. Available in PDF, EPUB and Kindle. Book excerpt: Showcases a novel method for approaching private international law combining theoretical insight, textual analysis and historical context.

Author : Peter Hay
Publisher : Foundation Press
ISBN 13 : 9781599416458
Total Pages : 0 pages
Book Rating : 4.5X/5 ( download)

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Download or read book Comparative Conflict of Laws written by Peter Hay and published by Foundation Press. This book was released on 2009 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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 courseâe(tm)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 partyâe(tm)s âeoepersonal law.âe 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

Author : Friedrich Juenger
Publisher : BRILL
ISBN 13 : 9004480439
Total Pages : 457 pages
Book Rating : 4.38/5 ( download)

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Download or read book Selected Essays on the Conflict of Laws written by Friedrich Juenger and published by BRILL. This book was released on 2021-10-25 with total page 457 pages. Available in PDF, EPUB and Kindle. Book excerpt: Friedrich K. Juenger on the conflict of laws is always worth attending to. Rejecting the "conventional wisdom" that prevails in the field, he sees the conflict of laws not as a discipline devoid of substantive values but as a powerful catalyst for multistate justice. Here is a wide-ranging collection of essays on a variety of problems posed by transactions that transcend state and national borders. The essays include a comparison of jurisdiction issues in the United States and the European Communities, opinions on forum shopping, a critique of interest analysis techniques, and a plea for a comparative approach to choice-of-law issues. Invaluable studies in the extraterritorial application of United States antitrust law, recognition of foreign money judgments and divorces, and regional conventions round out the collection. Published under the Transnational Publishers imprint.

Author : Mirjan R. Damaska
Publisher : Yale University Press
ISBN 13 : 0300191286
Total Pages : 440 pages
Book Rating : 4.88/5 ( download)

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Download or read book The Faces of Justice and State Authority written by Mirjan R. Damaska and published by Yale University Press. This book was released on 1991-07-24 with total page 440 pages. Available in PDF, EPUB and Kindle. Book excerpt: A leading legal scholar provides a highly original comparative analysis of how justice is administered in legal systems around the world and of the profound and often puzzling changes taking place in civil and criminal procedure. Constructing a conceptual framework of the legal process based on the link between politics and justice, Mirjan R. Damaska provides a new perspective that enables disparate procedural features to emerge as fascinating recognizable patterns. His book is "a significant work of scholarship . . . full of important insights."—Harold J. Berman

Author : Symeon Symeonides
Publisher : West Academic Publishing
ISBN 13 :
Total Pages : 952 pages
Book Rating : 4.49/5 ( download)

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Download or read book Conflict of Laws written by Symeon Symeonides and published by West Academic Publishing. This book was released on 2003 with total page 952 pages. Available in PDF, EPUB and Kindle. Book excerpt: Throughout the book, there is extensive information about the law and practice of other mostly civil-law countries that provides an opportunity for instructive comparative discussion. One chapter is devoted to international conflict, and another chapter is focused on conflict in cyberspace.

Author : Harold Cooke Gutteridge
Publisher : CUP Archive
ISBN 13 :
Total Pages : 232 pages
Book Rating : 4./5 ( download)

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Download or read book Comparative Law written by Harold Cooke Gutteridge and published by CUP Archive. This book was released on 1971 with total page 232 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Author : Zheng Sophia Tang
Publisher : Edward Elgar Publishing
ISBN 13 : 1849808597
Total Pages : 480 pages
Book Rating : 4.90/5 ( download)

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Download or read book Conflict of Laws in the People’s Republic of China written by Zheng Sophia Tang and published by Edward Elgar Publishing. This book was released on 2016-07-27 with total page 480 pages. Available in PDF, EPUB and Kindle. Book excerpt: The area of conflict of laws in China has undergone fundamental development in the past three decades and the most recent changes in the 2010s, regarding both jurisdiction and choice of law rules, mark the establishment of a modern Chinese conflicts system. Jointly written by three professors from both China and the UK, this book provides the most up-to-date and comprehensive analysis of Chinese conflict of laws in civil and commercial matters, covering jurisdiction, choice of law, procedure, judgment and awards recognition and enforcement, and interregional conflicts in China.

Author : Peter Hay
Publisher :
ISBN 13 : 9781634593083
Total Pages : 0 pages
Book Rating : 4.81/5 ( download)

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Download or read book Conflict of Laws written by Peter Hay and published by . This book was released on 2017 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: •Chapter 6, concerning the impact of the Constitution, has been streamlined to enhance “teachability.” The 2016 opinion in franchise tax Board versus Hyatt is now included as a principal case. •Chapters 7 and 8 present the central themes of choice of law. Both have been updated substantially. Chapter 8 has been considerably revised to show the progression from the traditional system, to the height of the conflicts revolution, to a developing consensus to consolidate modern analysis in a manner that provides more predictability and certainty. This revision is designed to give students -- most of whom have little or no familiarity with choice of law doctrine -- a b.