El Derecho Inglés y los Contratos Internacionales (book)
Sixto Sánchez Lorenzo is Professor of Private International Law at the University of Granada (Spain) and member of the International Academy of Comparative Law.
English Law is the preferred legal system in international contracts. Uniform texts as those proposed by UNIDROIT or the European Union have not managed to supersede a leadership grounded on cosmopolitism and liberalism that characterize English Law. However, the rules and principles of English Law often remain distant and enigmatic for civil lawyers. This book is oriented to Spanish-speaking lawyers and intends to provide a synthesis of English Contract Law, emphasizing its particular rules with comparative references to civil law systems. At the same time, it deals with English case-law on international contracts. Even though English courts make use of the same tool that others European judges (the Rome I Regulation), the analysis of the influence of English Private International Law on European rules facilitates the interpretation of these rules in other European countries, but also reveals some idiosyncratic particularities in its application by English courts. Finally, substantive and conflict-of-law rules can be hardly separated. For English lawyers who are able to read Spanish, the book provides, paraphrasing H.L.A. Hart, an “external statement“ about both English Contract Law and Private International Law of Contracts.
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