Party Autonomy in Contractual and NonContractual Obligations: A European and AngloCommon Law perspective on the freedom of cho,New

Party Autonomy in Contractual and NonContractual Obligations: A European and AngloCommon Law perspective on the freedom of cho,New

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SKU: DADAX3631653212
Brand: Peter Lang Gmbh, Internationaler Verlag Der Wissenschaften
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This study presents a comprehensive examination of party autonomy as provided for in the European Rome I Regulation and the Rome II Regulation. It follows an integrated method of analysis, whereby the principle of party autonomy as provided for in the Regulations is first compared with the preregulation position in Germany and England. This provides the basis for the subsequent critical reflection on the position of party autonomy in the Anglocommon law jurisdictions of Australia, New Zealand, Canada and Singapore. The study proposes that these European developments make an important contribution to the call for reform of the common law position concerning party autonomy in contractual, and more significantly, in noncontractual obligations.

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