Choose an application

• Reference Manager
• EndNote
• RefWorks (Direct export to RefWorks)

This book offers a contractual framework for the regulation of party autonomy in choice of law. The party autonomy rule is the cornerstone of any modern system of choice of law; embodying as it does the freedom enjoyed by parties to a cross-border legal relationship to agree on the law applicable to it. However, as this study shows, the rule has a major shortcoming because it fails to give due regard to the contractual function of the choice of law agreement. The study examines the existing law on choice of law agreements, by reference to the law of both common and civil law jurisdictions and international instruments. Moreover, it suggests a new coherent approach to party autonomy that integrates both the law of contract and choice of law. This important new study should be read with interest by private international law scholars

International private law --- Conflict of laws. --- Liberty of contract. --- Contracts pertaining to choice of law --- Conflict of laws --- Liberty of contract --- Contrats (Droit international privé) --- Liberté contractuelle --- Contracts

Choose an application

• Reference Manager
• EndNote
• RefWorks (Direct export to RefWorks)

The Brussels Ibis Regulation is to become by far the most prominent cornerstone of the European law of international civil procedure. Its imminence can be easily ascertained by every practitioner even remotely concerned with cross-border work in Europe. However arcane private international law in general might appear to practitioners – the Brussels I Regulation was a well-known and renowned instrument and the Brussels Ibis Regulation will become so as its proper heir. The so called Brussels system has proven its immeasurable and incomparable value for over forty years. The European Court of Justice and the national courts of the Member States have produced an abundance and a treasure of judgments interpreting the Brussels Convention and the Brussels I Regulation. The effort of completing a truly pan-European commentary mirrors the pan-European nature of its fascinating object. This commentary – which of course covers the jurisprudence of the ECJ in a comprehensive manner – assembles a team of very prominent and renowned authors from total Europe. The authors’ geographical provenience stretches from Denmark in the North to Italy in the South and from Portugal and the United Kingdom in the West to Austria in the East. Now the time is ripe to start such an enterprise. This commentary is the first full scale article-by-article commentary in English to address the Brussels Ibis Regulation. It is truly European in nature and style. It provides thorough and succinct in-depth analysis of every single Article and offers most valuable guidance for lawyers, judges and academics throughout Europe. It is an indispensable working tool for all practitioners involved in this field of law.

Conflict of laws --- Droit international privé --- European Parliament. --- Contrats internationaux --- Contrats --- Contracts (international law) --- Contracts --- Droit international privé (droit européen) --- Droit européen --- Droit international privé --- Jugements étrangers (droit européen) --- Conflit de juridictions --- Entraide judiciaire internationale --- Europees bevoegdheids- en executieverdrag. --- Erkenning buitenlandse vonnissen in burgerlijke en handelszaken. --- Verdrag betreffende de rechterlijke bevoegdheid en de tenuitvoerlegging van beslissingen in burgerlijke en handelszaken van 1988. --- Internationaal burgerlijk procesrecht. --- EU-landen. --- Europäische Union --- Conflict of laws. --- Europe --- Judicial assistance --- Judgments, Foreign --- Jurisdiction --- Executions (Law) --- Juridiction (Droit international privé) --- Assistance juridique internationale --- Jugements étrangers --- Juridiction --- Voies d'exécution --- Marriage law --- Procédure (droit européen) --- Choice of law --- Intermunicipal law --- International law, Private --- International private law --- Private international law --- Law --- Legal polycentricity --- Civil law --- Council of the European Union. --- European Parliarment. --- Contrats internationaux. --- Droit européen. --- Parent and child (Law) --- Custody of children --- Child custody --- Children --- Children, Custody of --- Parental custody --- Divorce --- Divorce mediation --- Guardian and ward --- Absentee fathers --- Absentee mothers --- Parental relocation (Child custody) --- Visitation rights (Domestic relations) --- Domestic relations --- Paternity --- Custody --- Law and legislation --- Procédure (droit européen) --- Jugements étrangers (droit européen) --- Droit international privé (droit européen) --- Contrats (droit européen) --- Contracts (International law) --- Entraide judiciaire européenne --- Voies d'exécution (Droit international privé) --- Procédure civile (Droit international privé) --- Executions --- Civil procedure --- Contrats (Droit international privé)