This book explores the application of foreign law in civil
proceedings in the British and German courts. It focuses on how
domestic procedural law impacts on the application of choice of law
rules in domestic courts. It engages with questions involved in the
investigation and determination of foreign law as they affect the
law of England and Wales, Scotland, and Germany. Although the
relevant jurisdictions are the focus, the comparative analysis
extends to explore examples from other jurisdictions, including
relevant international and European conventions. Ambitious in
scope, it expertly tracks the development of the law and looks at
possible future reforms.
General
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