STRECKER, S., 2014. Jurisdiction in, and the law applicable to, cross-border contractual obligations: the objectives and impact of the EU's legislative journey. PhD, Nottingham Trent University.
Download (1MB) | Preview
This thesis researches EU private international law rules relating to contracts, including its historical development, its rules and its policy objectives. In order to evaluate EU private international law and its policy objectives, English and Belgian private international law rules are investigated as exemplars of domestic law systems within the EU. In this approach lies one of the unique contributions to knowledge of the project. In particular the research takes an original and unique approach by investigating issues from an EU as well as a comparative national perspective. English and Belgian law represent different legal histories and systems (common law and civil law) and are therefore representative of the types of compromises that have to be made at an EU level. Moreover, the relevant legal instruments in the area of research have undergone some changes, some of which are significant and very recent. Particular reference must be made here to the Brussels I Regulation recast 2012. Due to its recent nature, very little publications are available, a gap the research wants to help fill by a detailed textual analysis of the relevant provisions. Finally, there is as of yet little detailed research on the EU’s policy objectives in the area of private international law. To some extent this holds true for English and Belgian law as well. The research aims to help fill that gap.
|Rights:||This work is the intellectual property of the author. You may copy up to 5% of this work for private study, or personal, non-commercial research. Any re-use of the information contained within this document should be fully referenced, quoting the author, title, university, degree level and pagination. Queries or requests for any other use, or if a more substantial copy is required, should be directed to the owner of the Intellectual Property Rights.|
|Divisions:||Schools > Nottingham Law School|
|Depositing User:||EPrints Services|
|Date Added:||09 Oct 2015 09:35|
|Last Modified:||09 Oct 2015 09:35|
Actions (login required)
Views per month over past year
Downloads per month over past year