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China Adopts Restrictive Theory of Foreign State Immunity

Conflict of Laws

For the law of state immunity, this move is particularly significant because China had been the most important adherent to the rival, absolute theory of foreign state immunity. In two prior posts ( here and here ), I discussed a draft of the FSIL (English translation here ). This provision also follows the U.N.

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Review of: PP Penasthika, Unravelling Choice of Law in International Commercial Contracts: Indonesia as an Illustrative Case Study (The Hague: Eleven Publishers 2022)

Conflict of Laws

The monograph predominantly examines 19 Indonesian court decisions on choice of law in international commercial contracts during the period, 2000-2020. Thus, in the Indonesian legal system, there is an interplay of civil law, which is inherited from the Dutch East Indies, adat (customary law), and Islamic law.