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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. Procedural law matters are reserved for the forum, and some Indonesian judges only appear to see the procedural aspects of choice of law.

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Praxis des Internationalen Privat- und Verfahrensrechts (IPRax) 3/2021: Abstracts

Conflict of Laws

Thirdly, by considering the impact on the UK’s and the EU’s relationships with third countries, with particular reference to the 2007 Lugano Convention and Hague Choice of Court Convention. The principal focus will be on questions of jurisdiction, the recognition and enforcement of judgments and choice of law for contract and tort.

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China Adopts Restrictive Theory of Foreign State Immunity

Conflict of Laws

Article 6, on the other hand, says that a foreign state shall not be deemed to have consented to jurisdiction by appearing in Chinese court to assert immunity, by having its representatives testify, or by choosing Chinese law to govern a particular matter. These provisions track Articles 7-9 of the U.N. Convention.

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Praxis des Internationalen Privat- und Verfahrensrechts (IPRax) 4/2021: Abstracts

Conflict of Laws

Supreme Court decision in March 2021 in Ford vs. Montana now permits the exercise of specific jurisdiction when the claim arises out of or is (sufficiently) “related” to the defendant’s in-state contacts and activities. This comment raises the question whether the decision reduces or in effect continues the previous uncertainty.

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Praxis des Internationalen Privat- und Verfahrensrechts (IPRax) 5/2022: Abstracts

Conflict of Laws

Contractual” duties of care corresponding with negligence in tort, on the other hand, fall within the scope of the Regulation Rome II. For the contracting parties as well as for third parties, the conflict-of-laws in claims following the disregard of such duties is determined by the application of Article 4 Regulation Rome II.

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A call for the wider study of Private International Law in Africa: A Review of Private International Law In Nigeria

Conflict of Laws

Successive Nigerian governments across all tiers have made the attraction of foreign investments a cardinal part of their economic policies and have accordingly made deliberate efforts and committed abundant resources to attract foreign investments into Nigeria. [1]

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