Treatment of Foreign Law - Dynamics towards Convergence?
- Springer International Publishing
- 2017
- Gebunden
- 660 Seiten
- ISBN 9783319565729
This work presents a thorough investigation of existing rules and features of the treatment of foreign law in various jurisdictions. Private international law (conflict of laws) and civil procedure rules concerning the application and ascertainment of foreign law differ significantly from jurisdiction to jurisdiction. Combining general and individual national reports, this volume demonstrates when and how foreign law is applied, ascertained, interpreted and reviewed by appeal courts. Traditionally, conflicts lawyers have been faced with two contrasting approaches. Civil law jurisdictions characterize foreign law as ¿law¿ and provide for the ex officio application and ascertainment of foreign law by judges. Common law jurisdictions consider foreign law as
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