Name: Place of Performance: A Comparative Analysis
Brand: Hart Publishing
SKU: 9781509936205
Price: 1387.10 HKD
Availability: InStock
Author: Chukwuma Okoli
ISBN: 9781509936205

Place of Performance: A Comparative Analysis

By Chukwuma Okoli

Hart Publishing May 2020

Specifications

ISBN-13: 9781509936205
Publisher: Hart Publishing
Publication: May 2020
Format: Hardback
Jurisdiction: U.K. ? Countri(es) for reference only

Also available as

Paperback

Details

This book provides an unprecedented analysis on the place of performance. The central theme is that the place of performance is of considerable significance as a connecting factor in international commercial contracts. This book challenges and questions the approach of the European legislator for not explicitly giving special significance to the place of performance in determining the applicable law in the absence of choice for commercial contracts. It also contains, inter alia, an analogy to matters of foreign country mandatory rules, and the coherence between jurisdiction and choice of law. It concludes by proposing a revised Article 4 of Rome I Regulation, which could be used as an international solution by legislators, judges, arbitrators and other stakeholders who wish to reform their choice of law rules.