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By providing a private international law analysis of a field in which international conventions coexist with national law and regional law, this book offers different theoretical and methodological insights into the conflict of laws and the conflict of jurisdictions, aiming ultimately at the juridical continuity of legal relations across national borders.
Central to the book is the jurisdictional function of arrest of ships. Forum arresti--the paradigmatic forum selection criterion in English and Scots law--has survived so far as a specific jurisdictional basis for maritime claims in the...