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A Study on a Global Jurisdiction and Judgments Convention

A Study on a Global Jurisdiction and Judgments Convention

Author: Dr Guangjian Tu
Publisher: Sweet & Maxwell Hong Kong
ISBN: 9789626613740
Published In: November 2009
Format: Paperback , 350 pages
Jurisdiction: International ? Disclaimer:
Countri(es) stated herein are used as reference only

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Description
Contents
Author

Details

"An analysis of why the Hague Judgments Project failed is of significant academic and practical merit … [This book] is of a most impressive standard… with first rate original analysis."

Professor Peter McEleavy, University of Dundee

"... a very useful way for readers to understand the current US and EU approaches to jurisdiction... [A]ll those interested in jurisdiction from a private international law perspective should find [this] stimulating to read"

Professor Paul R Beaumont, University of Aberdeen

International Civil and Commercial litigation practice often faces the problem of lacking a global jurisdiction and judgments convention. This book seeks to explore the deep conflicts between the US and the EU regarding jurisdictional issues and helps identify the true hurdles in reaching a global jurisdiction and judgments convention at The Hague.

Features

A critical examination of the domestic jurisdictional systems of the two main players, the US and EU at The Hague
An analysis on the respective advantages and disadvantages of the two systems
A revelation of the confrontation and the real difficulties at The Hague.

Benefits

Useful for readers to understand the background and current US and EU approaches to jurisdiction starting from scratch
Gives deep analysis and comparison on the topic as the book progresses supported by (i) case law of various jurisdictions including the EU, US, UK and other countries and (ii) official documents of international conventions
Provides inspiring suggestions and possible ways ahead
Suitable for academics, researchers, practitioners engaging in international litigation and students.

Introduction
Jurisdiction in civil and commercial matters in the US
Jurisdiction in civil and commercial matters in the EU – The Brussels Regime
A comparison, an assessment and a suggestion – from the perspective of legal tradition
A comparison, an assessment and a suggestion – from the perspective of fundamental approach
The confrontation in The Hague Conference on Private International Law
Conclusions

Dr. Guangjian Tu is an Assistant Professor of Law at the University of Macau specialising in private international law. He is a qualified lawyer and judge in the PRC and was awarded an LLM and a PhD in the UK.