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Choice of Law in the American Courts in 2022: Thirty-Sixth Annual Survey
The 36th Annual Survey of Choice of Law in the American Courts (2022) has been
Book: Intolerant Justice: Conflict and Cooperation on Transnational Litigation by Asif Efrat
Summary provided by the author, Asif Efrat In a globalized world, legal cases that come before domestic courts are often transnational, that is, they involve foreign elements. For example, the case before the court may revolve around events, activities, or situations that occurred in a foreign country, or the case may involve foreign parties or […]
Comparative Analysis of Doctrine of Separability between China and the UK
Written by Jidong Lin, Wuhan University Institute of International Law Background Separability is a world-recognized doctrine in commercial arbitration. It means that an arbitration clause is presumed to be a separate and autonomous agreement, reflecting contractual commitments that are independent and distinct from its underlying contract.
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Circulation of Personal Status – International symposium, January 19, 2024
An international symposium on the circulation of personal status be held on January 19, 2024 at the Italian Court of Cassation. The symposium is organized by the Société de législation comparée (
Van Den Eeckhout on CJEU case law in PIL matters – Follow up and a recently published paper
Veerle Van Den Eeckhout (working at the CJEU) has published a short article on recent CJEU case law in Private International Law matters. The paper is entitled “CJEU case law. A few observations on recent CJEU case law.” It has been published as a contribution to the fifth volume in the series of the
German Federal Court of Justice rules on what constitutes a genuine international element within the meaning of Art. 3(3) of the Rome I-Regulation (BGH, judgment of 29 November 2023, No. VIII ZR 7/23)
by Patrick Ostendorf (HTW Berlin) The principle of party autonomy gives the parties to a contract the opportunity to determine the applicable substantive (contract) law themselves by means of a choice-of-law clause – and thus to avoid (simple) mandatory rules that would otherwise bite. According to EU Private International law, however, the choice of the […]