Trevor Hartley, ‘Basic Principles of Jurisdiction in Private International Law: The European Union, The United States and England’

ABSTRACT
This article consists of a comparative study of the basic principles underlying the rules of jurisdiction in private international law in commercial cases in the law of the European Union, the United States and England. It considers the objectives which these rules seek to achieve (protection of the rights of the parties and respect for the interests of foreign States) and the extent to which these objectives are attained. It takes tort claims, especially in the field of products-liability, as an example and considers which system has the most exorbitant rules. It suggests explanations for the differences found.

Trevor C Hartley, Basic Principles of Jurisdiction in Private International Law: The European Union, The United States and England, International and Comparative Law Quarterly, https://doi.org/10.1017/S0020589321000427. Published online by Cambridge University Press: 11 November 2021.

First posted 2021-11-13 15:00:14

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