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Although the principle of party autonomy has become widely accepted, national law still diverges in many respects with regard to its scope, relevance, and limitations, leading to uncertainty for international trade. Choice of Law in International Commercial Contracts provides a dedicated and in-depth global comparative study of national and international rules and a definitive reference guide to the key choice of law principles on international contracts.
The work is framed by a comprehensive comparative report which sets out the similarities and differences between the featured national and international rules, comparing them with those of the Hague Principles and opening a discussion on further harmonisation. Dedicated chapters analyse the Principles as applied to international commercial arbitration, and place them within the historical and international perspectives of party autonomy. Finally, examining each jurisdiction in detail, the book presents sixty national and regional article-by-article commentaries on the Principles written by experts from all parts of the world.
The books is edited by Daniel Girsberger, Tenured Professor of Swiss and International Private, Business and Procedural Law, and Comparative Private Law, University of Lucerne; Thomas Kadner Graziano, Professor and Director of the Department of Private International Law and Director of the Programme on Transnational Law, University of Geneva; and Jan L Neels, Professor of Private International Law and Director of the Research Centre for Private International Law in Emerging Countries, University of Johannesburg