The Foreign Law problem: Choice of Law and European Integration
2006 (English)In: Essays in Tort, Insurance Law and Society in Honour of Bill W. Dufwa: Vol. 2, Stockholm: Jure Förlag AB , 2006, 629-643 p.Chapter in book (Refereed)
Very different practices are at present followed by the Member States of the EU regarding application of foriegn law. Much depends on the parties' own activities and the efforts they are prepared to make to have foreign law applied to the legal dispute at hand. As a result, unified rules on choice of law can very easily be set aside and remain a poor tool of integration.
It is argued that if common choice of law rules are to be taken seriously , they must be supplemented by harmonized rules on civil procedure in the Member States of the EU.
Place, publisher, year, edition, pages
Stockholm: Jure Förlag AB , 2006. 629-643 p.
Europeisk integration, lagval, processrätt
Law and Society
IdentifiersURN: urn:nbn:se:uu:diva-19468ISBN: 91-7223-251-XOAI: oai:DiVA.org:uu-19468DiVA: diva2:47240