Conflict Of Laws A Comparative Approach
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Conflict Of Laws A Comparative Approach
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Author : Cuniberti, Gilles
language : en
Publisher: Edward Elgar Publishing
Release Date : 2022-02-18
Conflict Of Laws A Comparative Approach written by Cuniberti, Gilles 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 2022-02-18 with Law categories.
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.
Preclassical Conflict Of Laws
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Author : Nikitas Hatzimihail
language : en
Publisher: Cambridge University Press
Release Date : 2021-07-22
Preclassical Conflict Of Laws written by Nikitas Hatzimihail 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 2021-07-22 with History categories.
Showcases a novel method for approaching private international law combining theoretical insight, textual analysis and historical context.
Comparative Law
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Author : Harold Cooke Gutteridge
language : en
Publisher: CUP Archive
Release Date : 1946
Comparative Law written by Harold Cooke Gutteridge and has been published by CUP Archive this book supported file pdf, txt, epub, kindle and other format this book has been release on 1946 with Comparative law categories.
Conflict Of Laws
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Author : Symeon Symeonides
language : en
Publisher: West Academic Publishing
Release Date : 2003
Conflict Of Laws written by Symeon Symeonides and has been published by West Academic Publishing this book supported file pdf, txt, epub, kindle and other format this book has been release on 2003 with Law categories.
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.
Selected Essays On The Conflict Of Laws
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Author : Friedrich Juenger
language : en
Publisher: BRILL
Release Date : 2021-10-25
Selected Essays On The Conflict Of Laws written by Friedrich Juenger and has been published by BRILL this book supported file pdf, txt, epub, kindle and other format this book has been release on 2021-10-25 with Law categories.
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.
The Oxford Handbook Of Global Legal Pluralism
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Author : Paul Schiff Berman
language : en
Publisher:
Release Date : 2020
The Oxford Handbook Of Global Legal Pluralism written by Paul Schiff Berman and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2020 with Law categories.
"Abstract Global legal pluralism has become one of the leading analytical frameworks for understanding and conceptualizing law in the twenty-first century"--
Conflict Of Laws In International Arbitration
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Author : Franco Ferrari
language : en
Publisher: Walter de Gruyter
Release Date : 2010-12-23
Conflict Of Laws In International Arbitration written by Franco Ferrari and has been published by Walter de Gruyter this book supported file pdf, txt, epub, kindle and other format this book has been release on 2010-12-23 with Law categories.
Irrespective of the increasing harmonization of law at the transnational level, every arbitration raises a number of confl ict of laws problems relating to procedural questions as well as to issues concerning the merits of the case. Unlike a state court judge, the arbitrator has no "lex fori" in the proper sense providing the relevant confl ict rules to determine the applicable law. This raises the question of what confl ict of laws rules to apply and, consequently, of the extent of the freedom the arbitrator enjoys in dealing with this and related issues. The best example of the importance of confl ict of laws questions in arbitration is the Vivendi-Elektrim saga where the outcome of the various proceedings depended on the question of characterization. This very beneficial book is dealing with - the arbitration agreement, - the jurisdiction of the arbitral tribunal, - the law applicable to the merits and - the arbitration procedure.
Comparative Tort Law
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Author : Mauro Bussani
language : en
Publisher: Edward Elgar Publishing
Release Date : 2021-02-26
Comparative Tort Law written by Mauro Bussani 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 2021-02-26 with Law categories.
This revised second edition of Comparative Tort Law: Global Perspectives offers an updated and enriched framework for analysing and understanding the current state of tort law around the world. Using a critical comparative methodology, it covers not only the common tort law issues but also many jurisdictions often overlooked in the mainstream literature. Contributions explore illuminating case studies from tort systems in Europe, the US, Latin America, Asia and sub-Saharan Africa, including new chapters specifically discussing tort law in Brazil, India and Russia.
The Oxford Handbook Of Comparative Law
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Author : Mathias Reimann
language : en
Publisher: Oxford University Press
Release Date : 2019-03-26
The Oxford Handbook Of Comparative Law written by Mathias Reimann and has been published by Oxford University Press this book supported file pdf, txt, epub, kindle and other format this book has been release on 2019-03-26 with Law categories.
This fully revised and updated second edition of The Oxford Handbook of Comparative Law provides a wide-ranging and diverse critical survey of comparative law at the beginning of the twenty-first century. It summarizes and evaluates a discipline that is time-honoured but not easily understood in all its dimensions. In the current era of globalization, this discipline is more relevant than ever, both on the academic and on the practical level. The Handbook is divided into three main sections. Section I surveys how comparative law has developed and where it stands today in various parts of the world. This includes not only traditional model jurisdictions, such as France, Germany, and the United States, but also other regions like Eastern Europe, East Asia, and Latin America. Section II then discusses the major approaches to comparative law - its methods, goals, and its relationship with other fields, such as legal history, economics, and linguistics. Finally, section III deals with the status of comparative studies in over a dozen subject matter areas, including the major categories of private, economic, public, and criminal law. The Handbook contains forty-eight chapters written by experts from around the world. The aim of each chapter is to provide an accessible, original, and critical account of the current state of comparative law in its respective area which will help to shape the agenda in the years to come. Each chapter also includes a short bibliography referencing the definitive works in the field.
Cross Border Transfers Of Undertakings
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Author : Kirsten Henckel
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2016-04-24
Cross Border Transfers Of Undertakings written by Kirsten Henckel and has been published by Kluwer Law International B.V. this book supported file pdf, txt, epub, kindle and other format this book has been release on 2016-04-24 with Law categories.
Globalization and market integration have shaped the economic climate in such a way as to give rise to a considerable increase in cross-border mergers, acquisitions and corporate restructurings. However, the primary European Union (EU) legislation in this area – the Acquired Rights Directive – brings about only partial and minimum harmonization, giving rise to differences in the employee protective regime across the EU Member States. This book, the rst full analysis of the EU-level private international law implications of the subject, masterfully addresses the plethora of questions that arise and presents well-considered and soundly based recommendations towards the introduction of a new and uniform con ict of laws path for transfers of undertakings throughout the EU. With a methodology that combines comparative, ‘black letter’, legal historical and empirical approaches, the author addresses such issues and topics as the following: – determination of applicable law both upon and after a transfer; – jurisdictional issues; – the main provisions of the Acquired Rights Directive and their content; – the main differences existing among the relevant laws of the Member States; – special characteristics of the maritime sector and seagoing workers; and – cross-border implications of Brexit. This book critically evaluates the existing rules on international jurisdiction and the con ict of laws relating to cross-border transfers of undertakings, clearly exposing the regime’s merits and demerits. Counsel representing any actor involved in a cross-border merger, acquisition, or business restructuring – transferor, transferee, or affected employees – will be well served with this exemplary account of their legal position both before and after the transfer. In addition, policymakers, legislators and interested academics will bene t greatly from the author’s clearly presented guidelines on the development of an EU-wide con ict of laws regime for transfers of undertakings.