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European private international law, as it stands in the Rome I, II, and III Regulations and the recent Succession Regulation, presents manifold risks of diverging judgments despite seemingly harmonised conflict of law rules. There is now a real danger, in light of the rapid increase in the number of legal instruments of the European Union on conflict of laws, that European private international law will become incoherent.This collection of essays by twenty noted scholars in the field sheds clear light on the pivotal issues of whether a set of overarching rules (a ‘general part’) is required, whether an EU regulation is the adequate legal instrument for such a purpose, which general questions such an instrument should address, and what solutions such an instrument should provide. In analysing the possible emergence of general principles in European private international law over the past years, the contributors discuss such issues and factors as the following:the relationship between conflict of laws and recognition;the room for party autonomy;the concept of habitual residence;adaptation when interplay between different laws leads to deadlock;public policy exceptions;the desirability of a general escape clause;the classic topics of characterisation, incidental question, and renvoi; andright to appeal in case of errors in the application of foreign law.Practitioners dealing with these notoriously difficult cases will welcome this in-depth treatment of the issues, as will interested policymakers throughout the EU Member States and at the EU level itself. Scholars will discover an incomparable comparative analysis leading to expert recommendations in European private international law, opening the way to an effective European framework in this area.

International private law --- Conflict of laws --- International and municipal law --- Conflict of laws. --- International and municipal law. --- Europe --- European Union --- Conflict of laws - European Union countries --- International and municipal law - European Union countries

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Will the new Rome I Regulation meet its goals - to improve the predictability of the outcome of litigation?- to bring certainty as to the law applicable and the free movement of judgments?- to designate the same national law irrespective of the country of the court in which an action is brought? The most important features of this instrument were outlined and discussed by distinguished legal experts from all over Europe and beyond at the conference "The Rome I Regulation", held in Verona on March 2009. This first book in English on the Rome I Regulation contains the papers submitted to that conference.

Law of obligations. Law of contract --- European law --- International private law --- Conflict of laws --- Contracts --- Obligations --- Torts --- European Parliament --- European Parliament. --- -Conflict of laws --- -346.02094 --- Uh5.4 --- Choice of law --- Intermunicipal law --- International law, Private --- Private international law --- Law --- Legal polycentricity --- Agreements --- Contract law --- Contractual limitations --- Limitations, Contractual --- Commercial law --- Legal instruments --- Obligations (Law) --- Juristic acts --- Liberty of contract --- Third parties (Law) --- -Obligations --- -Civil law --- Law and legislation --- Regulation (EC) No 593/2008 of the European Parliament and of the Council of 17 June 2008 on the law applicable to contractual obligations (Rome I). --- -Regulation (EC) No 593/2008 of the European Parliament and of the Council of 17 June 2008 on the law applicable to contractual obligations (Rome I). --- 346.02094 --- Civil law --- Council of the European Union. --- European Parliarment. --- E-books --- Entraide judiciaire européenne --- Conflict of laws - Contracts - European Union countries - Congresses --- Conflict of laws - Obligations - European Union countries - Congresses --- Conflict of laws - Torts - European Union countries - Congresses --- Contracts - European Union countries - Congresses --- Contrats

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European law --- International private law --- European Union --- Allemagne

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