Comparative Conflict Of Laws

Now in its second edition, and with significant updates and new material, Gilles Cuniberti’s innovative textbook offers a comparative treatment of private international law, a field of great importance in an increasingly globalized world. Written by a leading voice in the field, and using a text and cases approach, this text systematically presents and compares civil law and common law approaches to issues primarily within the United Kingdom, United States, France and the EU, as well as offering additional updated insights into rules applicable in other jurisdictions such as Japan, China and Germany.

Showcases a novel method for approaching private international law combining theoretical insight, textual analysis and historical context.

Throughout the book, there is extensive information about the law and practice of other mostly civil-law countries that provides an opportunity for instructive comparative discussion. One chapter is devoted to international conflict, and another chapter is focused on conflict in cyberspace.

"Abstract Global legal pluralism has become one of the leading analytical frameworks for understanding and conceptualizing law in the twenty-first century"--

The present volume reproduces with slight changes the course of lectures given at The Hague in 1972 under the title of "The General Principles of Private International Law". The substance of these lec tures has remained unaltered, but a number of insertions serve to cor rected some formal mistakes and misprints, added references to literature, some older, some more recent, without attempting to be exhaustive, and modified and supplemented the former exposition in two respects, where subsequent criticisms called for a review. The first concerns the place of public policy in Public International Law, the second deals with spatially-

This clear and authoritative introduction to the principles of a complex and rapidly changing area of the law now appears in a revised and updated form, with a completely new chapter on Trusts. The English conflict of laws is a body of rules whose purpose is to assist an English court in deciding a case which contains a foreign element. It consists of three main topics, which concern respectively: (i) the jurisdiction of the English courts, in the sense of their competence to hear and determine a case; (ii) the selection of the appropriate rules of a system of law, English or foreign, which it is to apply in deciding a case before it (the rules governing this selection are known as choice of law rules); and (iii) the recognition of and enforcement of judgments rendered by foreign courts, or awards of foreign arbitrations. It will continue to be a valuable text for students and practitioners alike.