Beschreibung
This study examines the principle party autonomy as provided for in the European Rome I Regulation and the Rome II Regulation. It critically reflects on the position of the freedom to choose the law in contract and tort in the common law jurisdictions of Australia, New Zealand, Canada and Singapore. It calls to reform the common law approach.
Autorenportrait
Maya Mandery holds an LL.B. (hons) from the University of Auckland (New Zealand), an LL.M. of the University of Würzburg and is Dr. iur (University of Cologne). Currently, she is a lecturer at the Faculty of Law at the University of Auckland.
Inhalt
Contents: Private International Law – Party Autonomy – Freedom of choice – Choice of law – Rome I Regulation on the law applicable to contractual obligations – Rome II Regulation on the law applicable to non-contractual obligations – Anglo-common law jurisdictions of Australia, New Zealand, Canada and Singapore – Pre-regulation position in Germany and England.
