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Comparative Conflict of Laws
Peter Hay
Russell J. Weintraub
Patrick J. Borchers
其他書名
Conventions, Regulations and Codes
出版
Thomson Reuters/Foundation Press
, 2009
主題
Law / Comparative
Law / Conflict of Laws
Law / Jurisprudence
ISBN
159941645X
9781599416458
URL
http://books.google.com.hk/books?id=YfCLPgAACAAJ&hl=&source=gbs_api
註釋
This regulations and codes title is designed to assist conflict of laws teachers in taking a comparative approach to the subject. International commercial transaction have become commonplace. Many injuries and deaths have their causes or their victims abroad. It is therefore imperative that the course in conflict of law include study of how foreign countries treat the course's major topics of judicial jurisdiction, choice of law, and recognition and enforcement of judgments. Interesting patterns emerge. Many choice-of-law codes and regulations have, as an exception to applying the law of the place of injury to torts, the law of the common domicile of the parties. In family-law related matters, there is much adherence to citizenship as a party's ?personal law.?domicile of the parties. Many examples could be given of the need for a comparative approach to conflict of laws. These materials, treaties, regulations, and codes from around the world, with questions and comments, will assist in taking that approach.