Conflict of Laws
  • About
  • Editorial board
  • Subscription
  • Submission
  • Materials
  • Contact
  • Click to open the search input field Click to open the search input field Search
  • Menu Menu

Second Issue of 2010’s Revue Critique de Droit International Privé

September 8, 2010/in /by Gilles Cuniberti
image_pdfimage_print

The last issue of the Revue critique de droit international privé was released in August. It contains two articles and several casenotes.

The first article is authored by Sara Godechot-Patris, who is a professor of law at the University of Tours. The article purports to revisit the concept of equivalence for the purpose of coordination of legal systems (Retour sur la notion d’équivalence au service de la coordination des systèmes). The English abstract reads:

Invoked in a myriad of different situations and in a confusing number of directions within the framework of the conflict of laws, the concept of equivalence  – which guarantees the integration within the forum legal order of situations conforming to foreign legal institutions – requires its use to be subject to greater discipline. This should take place by framing the conditions in which it operates, firstly through characterisation of the legal relationship, whether in view of the selection of a choice of law rule or in order to identify the substantive rules of the governing law, and secondly by subordinating the assessment to the requirements of coherence of the forum legal order. This will regulate its effects, not only in the case where an assessement of equivalence is positive and permits a substitution-assimilation or the subsidiarity application of the law of the forum, but also when the assessement is negative. In such a case, the refusal will not necessarily lead to a rejection of the foreign legal institution, since the necessary respect of the integrity of the forum legal order may lead to adding a new legal construct or category.

The second article is from Khalid Zaher,  who is a professor of law at the university of Fes (Morocco). It present the case for the recognition of Moroccan divorces after a recent decision of the French supreme court for private matters (Plaidoyer pour la reconnaissance des divorces marocains. A propos de l’arrêt de la première chambre civile du 4 novembre 2009). Unfortunately, there is no abstract.

The full table of content of the Revue can be seen here.

Share this entry
  • Share on Facebook
  • Share on X
  • Share on WhatsApp
  • Share on Pinterest
  • Share on LinkedIn
  • Share on Tumblr
  • Share on Vk
  • Share on Reddit
  • Share by Mail
https://conflictoflaws.net/News/2020/08/CoL_Banner-1.png 0 0 Gilles Cuniberti https://conflictoflaws.net/News/2020/08/CoL_Banner-1.png Gilles Cuniberti2010-09-08 14:40:542010-09-08 14:40:54Second Issue of 2010’s Revue Critique de Droit International Privé

Categories

  • Views
  • News

Most Recent Posts

  • Private International Law and European Society August 4, 2026
  • The New Zealand Supreme Court’s judgment in Kea Investments Ltd v Wikeley on anti-enforcement relief August 3, 2026
  • Beyond Domicile: The BHP Litigation and the Functional Interconnection of Public and Private International Law August 3, 2026
  • Conflicts of jurisdiction in Senegal: lesson from the Senegalese Supreme Court on Lis Pendens and the Exequatur of foreign judgments July 27, 2026
  • Adoption in the proposal for a European Parenthood Regulation July 21, 2026
  • Copyright, Targeting and Geo-Blocking: The CJEU Stirs the Pot July 15, 2026
  • A Follow-Up: The German Judges Association’s Response to the HCCH Draft Text of a Future Convention on Parallel Proceedings and Related Actions July 15, 2026
  • Private International Law Dimensions of Singapore’s New Legislation to Combat Online Harms July 14, 2026
  • The 1961 HCCH Apostille Convention: Why All African Countries Should Ratify It? — Insights from Judicial Practice in Africa July 14, 2026
  • The enforcement of an advance on costs for substitute performance at the expense of a Russian debtor in German-French legal relations July 2, 2026
  • “Yes, in principle, but not quite there yet…” – Some Observations on the Public Consultation on the HCCH Draft Text of a Future Convention on Parallel Proceedings and Related Actions June 29, 2026
  • Judgment Mobility Rules in India’s Private International Law Regime: No place for a revision au fond? June 26, 2026
  • Nothing to See Here: The CJEU’s Decision in Case C-232/25 Idzinski June 18, 2026
  • Refusal to Enforce in Egypt of a Californian (U.S.) Judgment for Lack of Reciprocity: What Has Gotten into the Egyptian Supreme Court? June 15, 2026
  • PRC Double Interest neither Double nor Penal: Australian Courts Clear Its Name When Enforcing Chinese Judgments June 10, 2026
Link to: Licari on Punitive Damages Link to: Licari on Punitive Damages Licari on Punitive Damages Link to: Proving Foreign Law in U.S. Federal Court: Is The Use Of Foreign Legal Experts “Bad Practice”? Link to: Proving Foreign Law in U.S. Federal Court: Is The Use Of Foreign Legal Experts “Bad Practice”? Proving Foreign Law in U.S. Federal Court: Is The Use Of Foreign Legal Experts...
Scroll to top Scroll to top Scroll to top