Anglo-American Perspectives on Private International Law
This monograph examines conflict of laws in the areas of family law, tort jurisdiction, choice of laws, and recognition and enforcement of foreign judgments. It provides an account of the common themes, related jurisprudence, and theoretical underpinnings that have guided Anglo-American traditions.
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The impediment grounds
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adopted American Anglo-American applied approach Article 5(3 Australia Borchers and Symeonides Brussels Convention choice of law Civil claim claimant common law Conflict of Laws Contracting corporations Court of Appeal damage decision defamation defendant defendant's determined dismissal dispute divorce recognition doctrine domicile domiciliary effect Enforcement of Foreign England English court English law European Family Law Act favour federal foreign court foreign judgment foreign plaintiffs forum non conveniens forum shopping fraud Hague Ibid injury interest analysis international comity issue judicial L.Rev Law Review law rules lex fori lex loci delicti liability libel litigation Lloyd's Rep Lord marriage North and Fawcett obtained parties personal jurisdiction perspective Piper Aircraft plaintiff principles Private International Law proceedings public policy recognition and enforcement relevant residence Shevill significant substantive supra supra n Supreme Court Symeonides talaq tort transnational U.S. courts U.S. Supreme Court United validity York