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Public Policy and Private International Law: A Comparative Guide

Public Policy and Private International Law: A Comparative Guide

Author: Olaf Meyer
Publisher: Edward Elgar Publishing
ISBN: 9781789902655
Published In: September 2022
Format: Hardback
Jurisdiction: U.K. ? Disclaimer:
Countri(es) stated herein are used as reference only

List Price: HKD 2,613.00

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Description
Contents

Details

The public policy exception in private international law is designed to provide a national backstop in the application of foreign laws. This book provides detailed and practical comparative coverage of the use of public policy in the context of private international law across a number of important jurisdictions spanning three continents.

As well as explaining the basic theoretical framework of the public policy exception in private international law, the book drills down into the practical application of such rules, giving an overview of these jurisdictions’ legal and policy stances on current issues including: punitive damages, surrogacy, same-sex marriage, gender-based discrimination, Islamic law, and adoption to name a few. This approach serves to highlight both the differences and the similarities in approach.

Key Features:

The first book to give a detailed practical treatment of the public policy exception in private international law
Coverage of 16 key jurisdictions
Two cross-cutting chapters that work through the comparative elements
Chapters written by experts in their respective jurisdictions

The book is the first to provide systematic jurisdictional coverage of the public policy exception and will be of immense value to notaries and practising lawyers navigating their way through this complex interaction. Academics and policy makers with a special interest in private international law will also find this an excellent platform for further research.

Preface

1. A Flexible System in Flux: On the Realignment of Public Policy

Olaf Meyer

2. Public Policy in European Private International Law

Wolfgang Wurmnest

3. Austria 48

Bea Verschraegen and Florian Heindler

4. Bosnia and Herzegovina 83

Zlatan Meškić and Anita Duraković

5. China 100

Fang Yu and Qiao Liu

6. England 120