Judgment recognition and enforcement (JRE) between the US states, between EU Member States, and between mainland China, Hong Kong, and Macao, are all forms of -interregional JRE.- This extensive comparative study of the three most important JRE regimes focuses on what lessons China can draw from the US and the EU in developing a multilateral JRE arrangement for mainland China, Hong Kong, and Macao. Mainland China, Hong Kong, and Macao share economic, geographical, cultural, and historical proximity to one another. The policy of -One Country, Two Systems- also provides a quasi-constitutional...

This book grew out of a major EU funded project on the Hague Maintenance Convention of 2007 and on the EU Maintenance Regulation of 2009. The project involved carrying out analytical research on the implementation into national law of the EU Regulation and empirical research on the first year of its operation in practice. The project also engaged international experts in a major conference on recovery of maintenance in the EU and worldwide in Heidelberg in March 2013. The contributions in the book are revised, refereed, and edited versions of the best papers that were presented at the...

This book offers a contractual framework for the regulation of party autonomy in choice of law. The party autonomy rule is the cornerstone of any modern system of choice of law; embodying as it does the freedom enjoyed by parties to a cross-border legal relationship to agree on the law applicable to it. However, as this study shows, the rule has a major shortcoming due to its failure to give due regard to the contractual function of the choice of law agreement. By looking at the existing law from several jurisdictions (including both common and civil law jurisdictions), and international...

Now available in paperback This book grew out of a major European Union funded project on the Hague Maintenance Convention of 2007 and on the EU Maintenance Regulation of 2009. The project involved carrying out analytical research on the implementation into national law of the EU Regulation and empirical research on the first year of its operation in practice. The project also engaged international experts in a major conference on recovery of maintenance in the EU and worldwide in Heidelberg March 2013. The contributions in this book are the revised, refereed and edited versions of the best...

The book will set out the challenges that the production for enforcement (or even so-called 'recognition') of such an unfamiliar foreign authentic instrument will pose to UK practitioners whether in contentious or non-contentious proceedings. The book takes a two part approach. In part one it will focus on an explanation of the nature of the foreign legal concept of an authentic instrument, setting out the modes of creation, typical domestic evidentiary effects and the typical domestic options to challenge such authentic instruments. Part two will then examine and analyse authentic...

Now available in paperback A nation's prosperity depends not only on the willingness of its businesses to export goods and services, and of its citizens and residents to travel to take advantage of opportunities overseas, but also on the willingness of the businesses and citizens of other nations to cross the nation's borders to do business. Economic expansion, and parallel increases in tourism and immigration, have brought Australians more frequently into contact with the laws and legal systems of other nations. In particular, in recent years, trade with partners in the Asia-Pacific Region...

"This constitutes a work of impressive scholarship that will become a major reference point for future discourse on choice of court agreements. Dr Ahmed advances a firm thesis in a lucid manner that will satisfy both academics and practitioners. The discussion is supported by a monumental foundation of underpinning research. Ahmed's monograph throughout shows clear understanding of underlying substantive laws and in Chapter 11 displays a refreshing willingness to engage in intelligent speculation on the implications of Brexit."--Prof. David Milman, U. of Lancaster. ***This book examines the...

No one would dispute that the duty to provide for those that you have a legal and moral obligation to support is very important. With the movement and migration of people both within Europe and globally, there are more and more families and relations who live in different States. Therefore it is imperative that suitable and workable methods exist to create maintenance obligations and then secure the transfer of funds, particularly from abroad. In the book the provisions in EU Maintenance Regulation no 4/2009 and the Hague Maintenance Convention of 2007 are analysed in order to discover what...

This substantial and original book examines how the EU Private International Law (PIL) framework is functioning and considers its impact on the administration of justice in cross-border cases within the EU. It grew out of a major project (ie EUPILLAR: European Union Private International Law: Legal Application in Reality) financially supported by the EU Civil Justice Programme. The research was led by the Centre for Private International Law at the University of Aberdeen and involved partners from the Universities of Freiburg, Antwerp, Wroclaw, Leeds, Milan and Madrid (Complutense). The...