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Implied Jurisdiction Agreements in International Commercial Contracts

Conflict of Laws

B Implied Jurisdiction Agreements Create Uncertainty for Business The main thesis of our article is that implied jurisdiction undermines the core needs of business entities engaging in cross-border commercial transactions. The Choice of Law Analogy Implied choice of law is well-established in private international law.

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Review of: PP Penasthika, Unravelling Choice of Law in International Commercial Contracts: Indonesia as an Illustrative Case Study (The Hague: Eleven Publishers 2022)

Conflict of Laws

The monograph predominantly examines 19 Indonesian court decisions on choice of law in international commercial contracts during the period, 2000-2020. Finally, this second chapter discusses the limits on choice of law, such as public policy and mandatory rules.

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“Other Appropriate Connections”: China’s Newly Adopted Jurisdiction Ground

Conflict of Laws

In terms of content, it has been suggested that indirect jurisdiction grounds, as outlined in the Hague Convention on the Recognition and Enforcement of Foreign Judgments in Civil or Commercial Matters 2019, should be considered. [6] 7] This method is further illustrated by judicial practices involving “other appropriate connections”.

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Zeitschrift für Vergleichende Rechtswissenschaft (ZVglRWiss) 122 (2023) Issue 3: Abstracts

Conflict of Laws

Phänomenologie und zivilrechtliche Einordnung von Kryptowährungen und anderen Kryptowerten Dörte Poelzig und Moritz Kläsener ZVglRWiss 122 (2023) 252–268 Crypto assets have been the subject of lively discussion in German civil law literature for several years now. However, no comprehensive regulation has been enacted to date.

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The Development of forum non conveniens in the Chinese Law and Practice

Conflict of Laws

Thirdly, no matter whether in common law jurisdictions or civil law jurisdictions, when applying the doctrines of forum non conveniens or lis pendens , the foreign courts upholding the jurisdiction is an important consideration for domestic courts to reject the exercise of ones own jurisdiction. Dr. Matthias Weller and Prof.

Laws 52
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A European Perspective on the Federalization of Shareholders’ Rights

Fordham Law News

The next paragraph aims at underlining the main characteristics of this fascinating experiment, namely the creation of a common European corporate law playing field, and at confronting it with the (missing) federalization of shareholders’ rights in the United States. Bebchuk, The Case for Increasing Shareholder Power , 118(3) Harv.

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The Need for an Uniform Civil Code in the Modern India

LexForti

Every religious practice has its civil law or particular law administrating its exclusive matters such as Marriage, Divorce, Maintenance, inheritance, and succession, etc. The Major Aspects Which Fabricated The Need For An Universal Civil Law. The differences are-. UCC From The Eyes of the Constitution of India.

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