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Examines restitution in private international law, including both the jurisdiction and choice of law questions facing restitutionary claims with international elements. This work provides an analysis of jurisdiction for restitutionary claims under both the Brussels Convention and common law rules.
The book opens with a brief summary of the English domestic law of restitution before going on to examine classification, or characterisation of restitutionary claims.;The central part of the book examines the choice of law rule for restitutionary issues, and reviews the different approaches adopted in the US and UK and in other parts of the common law world.