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9789041112347

Private International Law at the End of the 20th Century

by
  • ISBN13:

    9789041112347

  • ISBN10:

    9041112340

  • Format: Hardcover
  • Copyright: 1999-10-01
  • Publisher: Kluwer Law Intl
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Summary

This book provides a comparative assessment of the current state of private international law by exploring the fundamental philosophical, ideological, and methodological challenges encountered during the 20th century And The responses to those challenges in the western world. Among the questions discussed are: the dilemma between 'conflicts justice' and 'material justice'; the conflict between the goal of international uniformity And The need or desire to protect state or national interests; the tension between the goals of certainty and flexibility; the symbiosis of the multilateral, unilateral, and substantive methodologies; and the antagonism or co-existence between choice-of-law rules and flexible 'approaches', and between 'jurisdiction-selecting' and 'content-oriented' rules or approaches. Written by some of the world's most distinguished scholars, this thought-provoking book provides insightful and diverse perspectives from nineteen countries. it is essential reading for any teacher or student of private international law or comparative law.

Table of Contents

Preface vii
Sir Peter North
Foreword ix
Arthur T. von Mehren
Editor's Note xi
Symeon C. Symeonides
Part I: General Report 1(80)
General Report
3(78)
Symeon C. Symeonides
Part II: National Reports 81(398)
Australia
83(26)
Jianfu Chen
Belgium
109(18)
Marc Fallon
Johan Meeusen
Canada
127(20)
Alain Prujiner
Denmark
147(18)
Joseph Lookofsky
England
165(26)
Richard G. Fentiman
France
191(30)
Bernard Audit
Germany
221(22)
Hans Jurgen Sonnenberger
Greece
243(20)
Spyridon Vrellis
Hungary
263(16)
Laszlo Burian
Italy
279(16)
Fausto Pocar
Costanza Honorati
Netherlands
295(24)
Katharina Boele-Woelki
Carla Joustra
Gert Steenhoff
Norway
319(10)
Helge J. Thue
Poland
329(20)
Tomasz Pajor
Portugal
349(34)
Rui Manuel Moura Ramos
Switzerland
383(30)
Kurt Siehr
United States
413(32)
Courtland H. Peterson
Venezuela
445(16)
Tatiana B. de Maekelt
Yugoslavia
461(18)
Maja Stanivukovic
Appendix: General Reporter's Questionnaire 479(8)
Biographical Information 487(6)
Index 493

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