Comparative Analysis Law
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Codifying Choice Of Law Around The World
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Author : Symeon Symeonides
language : en
Publisher: Oxford University Press, USA
Release Date : 2014
Codifying Choice Of Law Around The World written by Symeon Symeonides and has been published by Oxford University Press, USA this book supported file pdf, txt, epub, kindle and other format this book has been release on 2014 with Law categories.
"The book is a comparative study of the choice-of-law codifications and convenƯ tions adopted in each of the inhabited continents in the last so years. Its main purpose is to document and inform rather than to critique. Although I do not always hide my opinion, I continue to act on the conviction that what we can learn from legislators is far more important than what they can learn from us" -- PREFACE.
Comparative Analysis Law
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Author : Katharina Schoenhoff
language : en
Publisher:
Release Date : 2013-09
Comparative Analysis Law written by Katharina Schoenhoff and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2013-09 with categories.
Seminar paper from the year 2012 in the subject Law - Comparative Legal Systems, Comparative Law, grade: 1,0, Anglia Ruskin University (Lord Ashroft International Business School), course: Comparative Business Law, language: English, abstract: In this paper Germany and the United Kingdom are comparatively analysed. The focus is on breach of duty as a part of negligence whose other aspects will be shortly illustrated as well. The aim of the paper is to show the differences between common law and civil law states by comparing a case that deals with the chosen aspect. The case that will be analysed deals with an accident in a wall climbing centre. It will be discussed if the centre acted negligent for omitted instructions to the customer. It will become clear that even though contributory action of the customer is considered the club still breached its duty to take reasonable care. Moreover the English case will be applied under the German procedure. Again, the club will be held liable for breaching its duty of care. Based on the analysis of the case under both legal systems the similarities and differences will be explained.
Rule Of Law And Fundamental Rights
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Author : Alfredo Narváez Medécigo
language : en
Publisher: Springer
Release Date : 2015-11-07
Rule Of Law And Fundamental Rights written by Alfredo Narváez Medécigo and has been published by Springer this book supported file pdf, txt, epub, kindle and other format this book has been release on 2015-11-07 with Law categories.
This book, which originated from the broadly held view that there is a lack of Rule-of-law in Mexico, and from the emphasis of traditional academia on cultural elements as the main explanation, explores the question of whether there is any relationship between the system of constitutional review ― and thus the ‘law’ as such ― and the level of Rule-of-law in a given state. To do so, it elaborates a theoretical model for achieving Rule-of-law and compares it to the constitutional review systems of the United States, the Federal Republic of Germany, and Mexico. The study concludes that the two former states correspond to the model, while the latter does not. This is fundamentally due to the role each legal system assigns to ordinary jurisdiction in carrying out constitutional review. Whereas the US and Germany have fostered the policy that constitutional review regarding the enforcement of basic rights is the responsibility of ordinary courts, Mexico has relied too heavily on the specialized constitutional jurisdiction.
Place Of Performance
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Author : Chukwuma Okoli
language : en
Publisher: Bloomsbury Publishing
Release Date : 2020-05-28
Place Of Performance written by Chukwuma Okoli and has been published by Bloomsbury Publishing this book supported file pdf, txt, epub, kindle and other format this book has been release on 2020-05-28 with Law categories.
This book provides an unprecedented analysis on the place of performance. The central theme is that the place of performance is of considerable significance as a connecting factor in international commercial contracts. This book challenges and questions the approach of the European legislator for not explicitly giving special significance to the place of performance in determining the applicable law in the absence of choice for commercial contracts. It also contains, inter alia, an analogy to matters of foreign country mandatory rules, and the coherence between jurisdiction and choice of law. It concludes by proposing a revised Article 4 of Rome I Regulation, which could be used as an international solution by legislators, judges, arbitrators and other stakeholders who wish to reform their choice of law rules.
The Powers Of Law
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Author : Mauricio García-Villegas
language : en
Publisher: Cambridge University Press
Release Date : 2018-05-03
The Powers Of Law written by Mauricio García-Villegas and has been published by Cambridge University Press this book supported file pdf, txt, epub, kindle and other format this book has been release on 2018-05-03 with Law categories.
García-Villegas compares the scholarship on the relationship between law, political power, and society in the United States and France.
The Legal Protection Of Databases
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Author : Estelle Derclaye
language : en
Publisher: Edward Elgar Publishing
Release Date : 2008-01-01
The Legal Protection Of Databases written by Estelle Derclaye and has been published by Edward Elgar Publishing this book supported file pdf, txt, epub, kindle and other format this book has been release on 2008-01-01 with Computers categories.
Dr Derclaye s book is well structured. . . the methodology is theoretical and comparative. . . Derclaye s work on database law is timely and readable, presenting a sound thesis to the perceived problems. Patricia Akester, Journal of Intellectual Property This book has a wide-ranging, detailed appeal for all lawyers, students and those in the public and private sectors. . . Richard Chambers . . . this book is a detailed, comprehensive and well-researched examination of legal protection of databases, which offers a valuable template for reform that will be of great interest to academics and policymakers alike. Tanya Aplin, European Intellectual Property Review The protection of the investment made in collecting, verifying or presenting database contents is still not harmonised internationally. Some laws over-protect database contents, whilst others under-protect them. This book examines and compares several methods available for the protection of investment in database creation namely, intellectual property, unfair competition, contract and technological protection measures in order to find an adequate type and level of protection. To this effect, the author uses criteria based on a combination of the economics of information goods, the human rights to intellectual property and to information, and the public interest, proposing a model that can be adopted at international and national levels. The Legal Protection of Databases will be of interest to intellectual property lawyers, competition lawyers, as well as general commercial lawyers because of the breadth of laws reviewed. It will also appeal to practitioners, policymakers, economists and students.
Comparing Law
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Author : Catherine Valcke
language : en
Publisher: Cambridge University Press
Release Date : 2018-10-25
Comparing Law written by Catherine Valcke and has been published by Cambridge University Press this book supported file pdf, txt, epub, kindle and other format this book has been release on 2018-10-25 with Law categories.
Reconstructs existing comparative law scholarship into a coherent analytic framework so as to both fend off current charges of theoretical arbitrariness and guide future work.
The Rule Of Law In Comparative Perspective
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Author : Mortimer Sellers
language : en
Publisher: Springer Science & Business Media
Release Date : 2010-07-23
The Rule Of Law In Comparative Perspective written by Mortimer Sellers and has been published by Springer Science & Business Media this book supported file pdf, txt, epub, kindle and other format this book has been release on 2010-07-23 with Law categories.
This volume compares the different conceptions of the rule of law that have developed in different legal cultures. It describes the social purposes and practical applications of the rule of law and how it might be improved in the varied circumstances.
Comparative Legal History
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Author : Olivier Moréteau
language : en
Publisher: Edward Elgar Publishing
Release Date :
Comparative Legal History written by Olivier Moréteau and has been published by Edward Elgar Publishing this book supported file pdf, txt, epub, kindle and other format this book has been release on with Law categories.
The specially commissioned papers in this book lay a solid theoretical foundation for comparative legal history as a distinct academic discipline. While facilitating a much needed dialogue between comparatists and legal historians, this research handbook examines methodologies in this emerging field and reconsiders legal concepts and institutions like custom, civil procedure, and codification from a comparative legal history perspective.
Groups Of Companies
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Author : Rafael Mariano Manóvil
language : en
Publisher: Springer Nature
Release Date : 2020-03-16
Groups Of Companies written by Rafael Mariano Manóvil and has been published by Springer Nature this book supported file pdf, txt, epub, kindle and other format this book has been release on 2020-03-16 with Law categories.
This book presents a comprehensive study on how twenty-three countries have approached the issue of company groups. In addition to detailed profiles of each country’s legislation, written by some of the most respected experts in the field, the book also presents a general overview and offers readers an in-depth, up-to-date and highly practical comparative analysis of the company group phenomenon in connection with national legal regimes. As such, the book is a must-read for all those seeking a deeper understanding of how company groups are viewed and regulated around the globe.