Subjects:

European Jurisdictions, Conflict of Laws

This work is a comparative examination of the uniform application of the Brussels and Lugano Conventions by courts in the UK, France, Germany and various other European countries. It analyses evidence of inconsistent or divergent interpretations of certain contentious articles of these Conventions and the experience of litigation under them in other (French- and German-speaking) jurisdictions. The book acts as a repository of information and offers a detailed examination of both academic commentary and case-law from the Convention jurisdictions together with an appraisal of the jurisprudence of the European Court of Justice. At appropriate points, it provides a bridge to the new regime under the Brussels I Regulation 44/2001 and Council Service Regulation 1348/2000, and the reforms under way in the draft Hague Worldwide Judgments Convention. The book should be useful to practitioners acting for clients on a pan-European basis.