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Praxis des Internationalen Privat- und Verfahrensrechts (IPRax) 5/2023: Abstracts

Conflict of Laws

This decision provides an opportunity to examine the prerequisites and legal consequences of apparent establishments and so-called virtual establishments (internet presences) from a general perspective, both in the context of Article 7 (5) Brussels Ia Regulation and in connection with Article 19 (2) Rome I Regulation. Notifications: C.

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Dubai Supreme Court Admits Reciprocity with the UK and Enforces an English Judgment

Conflict of Laws

2) The foreign judgment is contrary to public policy because it violates Islamic Sharia law, individual property rights and the distribution of property under UAE law. 3) The parties have not (yet) been divorced under Pakistani law or Islamic Sharia. 37 (2023), pp. This decision was later upheld by the DSC ( Appeal No.

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The Abu Dhabi Civil Family Court on the Law on Civil Marriage – Applicability to Foreign Muslim and the Complex Issue of International Jurisdiction

Conflict of Laws

Introduction In a previous post , I reported and commented on a decision rendered by the Abu Dhabi Supreme Court (hereinafter “ADSC”) in which the Court addressed the issue of the applicability of the Abu Dhabi Civil Marriage Law (Law No. In its judgment, the ADFCF refers to the contract dated 7 December 2023 ).

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Bahraini High Court on Choice of Court and Choice of Law Agreements

Conflict of Laws

Similarly, the foreign law chosen as the governing law of a contract is often not applied because of the procedural status of foreign law as a matter of fact, the content of which must be ascertained by the party invoking its application. Pursuant to Article 4 of Law No. Weller et al.

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