Marriage In Comparative Conflict Of Laws

The rights & obligations of parenthood are central to most people's lives. Yet their form & substance are caught up in the great demographic, social & economic changes of the late twentieth century. In this book, specialists from 22 countries examine fundamental issues confronting parenthood: these include social & biological conceptions of parenthood; the legal & moral obligations of parenthood; the legal & scientific establishment of parentage; rights to parenthood, including inter-country adoption; the effects on parent--child relationships of family change; the role of the state in family life; the position of minorities; & children's rights. They are viewed within a global context, & integrated in a commentary which looks forward to the future evolution of the law.

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.