Conflict of Laws
MARCH 15, 2022
Should courts in the United States refuse to recognize and enforcement Chinese court judgments on the ground that China does not provide impartial tribunals or procedures compatible with the requirements of due process of law? Last April, a New York trial court said yes in Shanghai Yongrun Investment Management Co. Wan , a U.S.
Conflict of Laws
AUGUST 29, 2024
Spanning 226 pages across six chapters, the book aims to be the leading English-language text on private international law in Indonesia. Indonesia, a civil law country, has legal principles influenced by Dutch traditional private international law, owing to its colonial history.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.
Conflict of Laws
MARCH 23, 2024
It evidently has not stopped claimants from seeking enforcement of punitive damage awards in other civil law legal systems. He argued that punitive damages seem to be one of the few legal institutions showing a sharp contrast between common law and civil law jurisdictions.
Conflict of Laws
JULY 11, 2021
Having chosen instead (b) arbitration, the parties will normally make explicit the ‘seat’ (London, Milan, New York, etc) and the size of the arbitral tribunal (one, three, five, etc). In the last few decades, even civil law jurisdictions have witnessed an increase in the promotion of alternative dispute resolution.
InHouseOps
JUNE 13, 2022
Remember, these are cases that could involve parties from common law and civil law countries. In fact, we include such language in the award because in the New York Convention, for example, the US has taken a reservation to that treaty that it will enforce the awards based on reciprocity.
Conflict of Laws
SEPTEMBER 22, 2023
The first panel will focus on global and comparative private international law. The second panel will examine contemporary English conflict of laws, through the lens of Trevor’s famous ICLQ article on the systematic dismantling of the common law of conflict of laws.
Conflict of Laws
DECEMBER 16, 2024
10), which according to Franzina was designed not primarily with civil law systems in mind, but rather for common law jurisdictions, who were assumed to have difficulties in asserting the public policy exception (Art. 7 (1) lit. While reminding the audience of the importance of an autonomous interpretation (Art.
Expert insights. Personalized for you.
40 
Let's personalize your content