This book is the first one in English to focus in-depth upon the private international law problems raised by the sale of goods. It begins with the substantive law and practice, and uses this as the basis for a comparative and critical discussion of the private international law issues. Examples of the typical obligations of the buyer and seller are also provided. International Sale of Goods in the Conflict of Laws is a strong new addition to the Oxford Private International Law Series and covers everything from torts to e-commerce.
This book is the first one in English to focus in-depth upon the private international law problems raised by the sale of goods. It begins with the su...
This book comprehensively analyses the relevant legislative practice of all major arbitration venues in the world, as well as the arbitral practice of a number of arbitral institutions. The book proposes an analytical model for the determination of the procedural law of international arbitration, as well as a number of 'model' legislative provisions of substantive and private international law.
This book comprehensively analyses the relevant legislative practice of all major arbitration venues in the world, as well as the arbitral practice of...
This book deals with the problems generated by those cases of insolvency (either of an individual or of a company) involving more than one system of law, that bring into operation the principles and methods of private international law. The author provides guidance on the ways in which workable solutions to practical problems can be achieved using national and international remedies now available, including assistance available from foreign courts. Both English and international law is covered in detail, including the EC Regulation on Insolvency Proceedings, in force throughout the UK since...
This book deals with the problems generated by those cases of insolvency (either of an individual or of a company) involving more than one system of l...
This work provides an analysis of how foreign law should be pleaded and dealt with in the litigation process of another country. What weight should the trial court give to the relevant foreign law, and how should it decide what the foreign law actually is? The way foreign law is procedurally treated in court indicates to a certain extent the degree of tolerance of a legal system towards foreign ideas. The book compares how these issues are handled in different national systems, with particular focus upon civil litigation rules in the US, UK, France, Germany, the Netherlands and Belgium.
This work provides an analysis of how foreign law should be pleaded and dealt with in the litigation process of another country. What weight should th...
This book covers the development and current position of civil jurisdiction rules in the EU, with an analysis of the three main regulations on civil jurisdiction and the effect of these rules on parties domiciled or habitually resident outside the EU, particularly with regard to the recognition and enforcement of judgments made within the EU in external jurisdictions. The book also looks into the institutional issue of external relations the European Community maintains with third States, principally how these third States are able to conclude international agreements with EU Member...
This book covers the development and current position of civil jurisdiction rules in the EU, with an analysis of the three main regulations on civil j...
This book provides a detailed and up-to-date exposition of English and Scottish rules of choice of law in inter vivos transfers of property. It traces the development of the lex situs rule, and its application to inter vivos dealings with immovable property, tangible movable property (including the special case of cultural property), and intangible movable property (including indirectly held securities). The author offers two alternative models of suggested choice of law rules in property, introducing a greater degree of flexibility into choice of law rules in property, and formulates...
This book provides a detailed and up-to-date exposition of English and Scottish rules of choice of law in inter vivos transfers of property. It traces...
This book analyzes the law and practice relating to the classification, drafting, validity and enforcement of contracts relating to jurisdiction and choice of law. The focus is on English law, EU law and common law measures, but there is also some comparative material built in. The book will be useful in particular to practicing lawyers seeking to draft, interpret or enforce the types of contract discussed, but the in-depth discussion will also be valuable to academic lawyers specializing in private international law. Written by an academic who is also a practicing barrister, this book...
This book analyzes the law and practice relating to the classification, drafting, validity and enforcement of contracts relating to jurisdiction and c...
This book provides a comprehensive but concise analysis of all the relevant principles and case-law surrounding anti-suit injunctions. Particular emphasis is given to addressing the practical problems that are likely to confront a practitioner applying for or resisting an anti-suit injunction in urgent circumstances.
This book provides a comprehensive but concise analysis of all the relevant principles and case-law surrounding anti-suit injunctions. Particular emph...