Application of Foreign Law : /
Application of Foreign Law : /
ed. by Carlos Esplugues Mota, José Luis Iglesias Buhigues, Guillermo Palao Moreno.
- 1 online resource (409 p.)
Frontmatter -- Table of Contents -- List of Authors -- Preface: The Project -- List of Abbreviations -- Chapter 1 -- General Report on the Application of Foreign Law by Judicial and Non-Judicial Authorities in Europe (Project JLS / CJ / 2007-1 / 03) -- “Principles for a Future EU Regulation on the Application of Foreign Law (“The Madrid Principles”) -- Chapter 2 -- Austria and Germany -- Baltic Countries -- Belgium -- Bulgaria -- Cyprus -- Czech Republic and Slovak Republic -- France -- Greece -- Hungary -- Ireland -- Italy -- Luxembourg -- Malta -- Poland -- Portugal -- Romania -- Scandinavian Countries -- Slovenia -- Spain -- The Netherlands -- United Kingdom
restricted access http://purl.org/coar/access_right/c_16ec
During the last decade Europe has undertaken an active and broad process of harmonisation of choice-of-law rules within the EU. However, this drastic movement towards a harmonised system has so far left aside a highly relevant issue: the application by judicial and non-judicial authorities of the foreign law. In full contrast to the little attention so far paid to it in the EU, this issue is said to be the crux of the conflict of laws. It violates legal certainty and contradicts the objective of ensuring full access to justice to all European citizens within the EU. This book provides a comparative study of the existing situation in all EU member states and drafts some basic principles for a future European instrument. It will become a highly useful tool for lawyers, judges, notaries, land registries, academics, prosecutors etc.
Mode of access: Internet via World Wide Web.
In English.
9783866539129
10.1515/9783866539129 doi
Conflict of laws--European Union countries.
Foreign law, Pleading and proof of--European Union countries.
LAW / International.
KJC976 / .A96 2011eb
347.42077
Frontmatter -- Table of Contents -- List of Authors -- Preface: The Project -- List of Abbreviations -- Chapter 1 -- General Report on the Application of Foreign Law by Judicial and Non-Judicial Authorities in Europe (Project JLS / CJ / 2007-1 / 03) -- “Principles for a Future EU Regulation on the Application of Foreign Law (“The Madrid Principles”) -- Chapter 2 -- Austria and Germany -- Baltic Countries -- Belgium -- Bulgaria -- Cyprus -- Czech Republic and Slovak Republic -- France -- Greece -- Hungary -- Ireland -- Italy -- Luxembourg -- Malta -- Poland -- Portugal -- Romania -- Scandinavian Countries -- Slovenia -- Spain -- The Netherlands -- United Kingdom
restricted access http://purl.org/coar/access_right/c_16ec
During the last decade Europe has undertaken an active and broad process of harmonisation of choice-of-law rules within the EU. However, this drastic movement towards a harmonised system has so far left aside a highly relevant issue: the application by judicial and non-judicial authorities of the foreign law. In full contrast to the little attention so far paid to it in the EU, this issue is said to be the crux of the conflict of laws. It violates legal certainty and contradicts the objective of ensuring full access to justice to all European citizens within the EU. This book provides a comparative study of the existing situation in all EU member states and drafts some basic principles for a future European instrument. It will become a highly useful tool for lawyers, judges, notaries, land registries, academics, prosecutors etc.
Mode of access: Internet via World Wide Web.
In English.
9783866539129
10.1515/9783866539129 doi
Conflict of laws--European Union countries.
Foreign law, Pleading and proof of--European Union countries.
LAW / International.
KJC976 / .A96 2011eb
347.42077