Entries by Giesela Ruehl

Out now: RabelsZ 83 (2019), Issue 1

The latest issue of RabelsZ has just been released. It contains the following articles: Kutner, Peter, Recognition and Enforcement of Foreign Judgements – The Common Law’s Jurisdiction Requirement, pp. 1 et seq The “Dicey Rule” has been treated as canonical in England and elsewhere. However, it has changed over time, it has been based in […]

Out now: ZEuP 2019, Issue 1

The latest issue of the Zeitschrift für Europäisches Privatrecht has just been released. It  contains the following articles (plus an interesting editorial by Heike Schweizer on the platforms as “private regulators”): Francisco Garcimartín: The EU Regime on Securitisation: coordination between the regulatory framework and the conflict of law rules This article analyses the relationship between […]

Sweden: New rules on non-recognition of underage marriages

Written by Prof. Maarit Jänterä-Jareborg, Uppsala University, Sweden On 1 January 2019, new restrictions came into force in Sweden’s private international law legislation in respect of marriages validly concluded abroad. The revised rules are found in the Act (1904:26 p. 1) on Certain International Relationships on Marriage and Guardianship, Chapter 1 § 8a, as amended by […]

After the Romans: Private International Law Post Brexit

Written by Michael McParland, QC, 39 Essex Chambers, London On 10 December 2018 the Ministry of Justice published a draft statutory instrument with the pithy title of “The Law Applicable to Contractual Obligations and Non-Contractual Obligations (Amendment etc) (EU Exit) Regulations 2018”. This indicates the current intended changes to retained EU private international law of […]

The renaissance of the Blocking Statute

Written by Markus Lieberknecht, Institute for Comparative Law, Conflict of Laws and International Business Law (Heidelberg) Quite a literal “conflict of laws” has recently arisen when the EU reactivated its Blocking Statute in an attempt to deflect the effects of U.S. embargo provisions against Iran. As a result, European parties doing business with Iran are […]