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Public Policy and Private International Law: A Comparative Guide

Public Policy and Private International Law: A Comparative Guide

  • 作者:
  • 出版商: Edward Elgar Publishing
  • ISBN: 9781789902655
  • 出版时间 September 2022
  • 规格: Hardback
  • 适应领域: U.K. ? 免责申明:
    Countri(es) stated herein are used as reference only

List Price: RM1,332.38

RM1,292.41 Save RM39.97 (3%)

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  • 描述 
  • 大纲 
  • 详细

    The public policy exception in private international law is designed to provide a national backstop in the application of foreign laws. This book provides detailed and practical comparative coverage of the use of public policy in the context of private international law across a number of important jurisdictions spanning three continents.

    As well as explaining the basic theoretical framework of the public policy exception in private international law, the book drills down into the practical application of such rules, giving an overview of these jurisdictions’ legal and policy stances on current issues including: punitive damages, surrogacy, same-sex marriage, gender-based discrimination, Islamic law, and adoption to name a few. This approach serves to highlight both the differences and the similarities in approach.

    Key Features:

    • The first book to give a detailed practical treatment of the public policy exception in private international law
    • Coverage of 16 key jurisdictions
    • Two cross-cutting chapters that work through the comparative elements
    • Chapters written by experts in their respective jurisdictions

    The book is the first to provide systematic jurisdictional coverage of the public policy exception and will be of immense value to notaries and practising lawyers navigating their way through this complex interaction. Academics and policy makers with a special interest in private international law will also find this an excellent platform for further research.

  • Preface
    1. A Flexible System in Flux: On the Realignment of Public Policy
    Olaf Meyer
    2. Public Policy in European Private International Law
    Wolfgang Wurmnest
    3. Austria 48
    Bea Verschraegen and Florian Heindler
    4. Bosnia and Herzegovina 83
    Zlatan Meškić and Anita Duraković
    5. China 100
    Fang Yu and Qiao Liu
    6. England 120
    Louise Merrett
    7. France 162
    Cécile Pellegrini
    8. Germany 191
    Peter Mankowski and Svenja Langenhagen
    9. Hungary 224
    Réka Somssich
    10. Italy 242
    Pietro Franzina
    11. Poland 270
    Maciej De Abgaro Zachariasiewicz
    12. Portugal 300
    Luís de Lima Pinheiro
    13. Russia 319
    Madina Kassenova
    14. Spain 353
    Nicolás Zambrana-T.var and Alberto Muńoz Fernéndez
    15. Sweden 374
    Ulf Maunsbach
    16. Switzerland 390
    Andreas Furrer and Dirk Trüten
    17. Turkey 420
    Candan Yasan-Tepetaş
    18. United States 438
    John F. Coyle

    Index

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