This work is a comparative examination of the uniform application of the Brussels and Lugano Conventions by courts in the UK, France, Germany, and various other European countries. It analyzes evidence of inconsistent or divergent interpretations of certain contentious articles of these Conventions and the experience of litigation under them in other (French and German-speaking) jurisdictions. The book acts as a unique repository of information and offers a detailed examination of both academic commentary and case-law from the Convention jurisdictions together with a critical appraisal of the...
This work is a comparative examination of the uniform application of the Brussels and Lugano Conventions by courts in the UK, France, Germany, and var...