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Vol 21 No 9 Sept/Oct 2016

Book of the Month

Cover of Goode on Commercial Law

Goode on Commercial Law

Edited by: Ewan McKendrick
Price: £170.00

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EU Law and Private International Law: The Interrelationship in Contractual Obligations

ISBN13: 9789004206731
Published: December 2011
Publisher: Martinus Nijhoff Publishers
Country of Publication: The Netherlands
Format: Hardback
Price: £105.00

Despatched in 14 to 16 days.

The Rome I Regulation on the Law Applicable to Contractual Obligations has unified the conflict of laws rules of the Member States. The influence of the European Union upon Private International Law goes however beyond positive harmonisation.

There is a certain tension between European law and PIL. European law is concerned with whether the imposition of a rule constitutes a restriction to the internal market whereas PIL does not seek to neutralise the disadvantages that result from differences between national laws but instead tries to locate the geographical centre of the legal relationship.

The present book attempts to identify the methodological disharmony between the two legal disciplines in the regulation of cross border contracts and proposes suggestions to enhance their mutual understanding.