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A Study on a Global Jurisdiction and Judgments Convention

By Dr Guangjian Tu
Sweet & Maxwell Hong Kong November 2009

Specifications

ISBN-13
9789626613740
Publisher
Sweet & Maxwell Hong Kong
Publication
November 2009
Format
Paperback , 350 pages
Jurisdiction
International ? Countri(es) for reference only

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.

 

Table of Contents

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

About the Author

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.

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