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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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China Adopts Restrictive Theory of Foreign State Immunity

Conflict of Laws

Supreme Court has held that issuing foreign government bonds is a commercial activity, even if done for a sovereign purpose. It is unclear if Chinese courts applying the FSIL will reach the same conclusion. The FSIL’s reciprocity clause is consistent with the emphasis on reciprocity that one finds in other provisions of Chinese law.

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

Conflict of Laws

On applicable law for environmental pollution (Article 7 Rome II), a pinnacle of business and human rights as well as climate change litigation. The European Union rules on the law that applies to liability for environmental damage, are an outlier in the private international law agenda.

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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

The result of the authors’ analyses of Nigerian appellate courts’ cases bordering on the jurisdiction of Nigerian courts in actions in personam arising from causes of action which accrue outside the territorial jurisdiction of the courts is particularly eye-opening.

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