Thomas Kadner Graziano - Böcker

Although the possibility of making a choice of law in respect of international commercial contracts has become widely accepted, national law still diverges in many respects with regard to the scope and relevance of, and the limitations on, party autonomy, leading to uncertainty in international commercial relations. This book compares the Hague Principles on Choice of Law in International Commercial Contracts (2015) with national, regional, supranational, and international rules on choice of law around the world in order to chronicle the divergent approaches which exist today. The work is introduced by a comprehensive comparative report which sets out the similarities and differences between the featured national, regional, supranational, and international rules, comparing such rules with those of the Hague Principles, thereby initiating a discussion on further harmonization in the field. Another report focuses on the application of the Hague Principles in the context of international commercial arbitration. Dedicated chapters analyse the Hague Principles from a historical, theoretical, and international organizational point of view. Finally, examining each jurisdiction in detail, the book presents sixty national and regional article-by-article commentaries on the Hague Principles written by experts from all parts of the world. This dedicated and in-depth global comparative study of national, regional, supranational, and international rules provides a definitive reference guide to the key principles in respect of choice of law for international commercial contracts.

Comparative Contract Law is the thoroughly revised fourth edition of a widely acclaimed and well-established textbook. It brings together extracts from legislation and court practice in case studies and promotes a ‘learning-by-doing’ approach to comparative methodology, enabling students to experience comparative law in action. The book acts as a practical guide for those seeking to familiarise themselves with real-world materials and to better understand the diverse approaches to modern contract law.Key Features:A comparative perspective on highly topical, real-life issues of contract lawMaterials from some 30 jurisdictions in both their original languages and high quality translationsStudents are able to solve scenarios according to the laws of different jurisdictions, to compare and evaluate the solutions and approaches they identify, and to better understand the diverse approaches to modern contract lawNEW! Full integration of the new Belgian Civil Code and information on small and medium-sized jurisdictions further diversified

Comparative Contract Law is the thoroughly revised fourth edition of a widely acclaimed and well-established textbook. It brings together extracts from legislation and court practice in case studies and promotes a ‘learning-by-doing’ approach to comparative methodology, enabling students to experience comparative law in action. The book acts as a practical guide for those seeking to familiarise themselves with real-world materials and to better understand the diverse approaches to modern contract law.Key Features:A comparative perspective on highly topical, real-life issues of contract lawMaterials from some 30 jurisdictions in both their original languages and high quality translationsStudents are able to solve scenarios according to the laws of different jurisdictions, to compare and evaluate the solutions and approaches they identify, and to better understand the diverse approaches to modern contract lawNEW! Full integration of the new Belgian Civil Code and information on small and medium-sized jurisdictions further diversified

Comparative Tort Law promotes a ‘learning by doing’ approach to comparative tort law and comparative methodology. Each chapter starts with a case scenario followed by questions and expertly selected material, such as: legislation, extracts of case law, soft law principles, and (where appropriate) extracts of legal doctrine. Using this material, students are invited to: • solve the proposed scenario according to the laws of several jurisdictions; • compare the approaches and solutions they have identified; • evaluate their respective pros and cons; and • reflect upon the most appropriate approach and solution. This book is essential reading for all students and scholars of comparative tort law and comparative law methodology and is the ideal companion for those wishing to both familiarise themselves with real-world materials and understand the many diverse approaches to modern tort law.

Comparative Tort Law promotes a ‘learning by doing’ approach to comparative tort law and comparative methodology. Each chapter starts with a case scenario followed by questions and expertly selected material, such as: legislation, extracts of case law, soft law principles, and (where appropriate) extracts of legal doctrine. Using this material, students are invited to: • solve the proposed scenario according to the laws of several jurisdictions; • compare the approaches and solutions they have identified; • evaluate their respective pros and cons; and • reflect upon the most appropriate approach and solution. This book is essential reading for all students and scholars of comparative tort law and comparative law methodology and is the ideal companion for those wishing to both familiarise themselves with real-world materials and understand the many diverse approaches to modern tort law.

Since the adoption of the EU Regulation on Insolvency Proceedings in 2000 and its recast in 2015, it has become clear that lawyers engaged in consumer insolvency proceedings are increasingly expected to have a basic understanding of foreign insolvency proceedings, as well as knowledge of the foreign country's court and legal system, legislation and judicial practice. Written by 50 highly qualified insolvency experts from 30 European countries, A Guide to Consumer Insolvency Proceedings in Europe provides the necessary information in the largest, most up-to-date and comprehensive book on this topic.Assisting the readers in their navigation through the differences, similarities, and peculiarities of insolvency proceedings in all Member States of the European Union, Switzerland and Russia, this book is a unique guide to insolvency proceedings across Europe. With contributions by both academics and practitioners, it provides truly multinational coverage of the economic, legal, social, political, and demographic issues in consumer insolvency. Illustrating the numerous practices across Europe, this book allows the reader to evaluate each aspect both on its own merits, as well as in comparison to the approaches applied in other European jurisdictions.This book will be an invaluable tool for insolvency practitioners, judges, lawyers, creditors and debtors throughout Europe, especially those participating in cross-border proceedings.Contributors include: E. Andreeva, R. Bodis, J. Bojars, C. Booth, D. Cerini, A. Demetriadi, M. Dordevic, K. Farry, O. Fromholdt, E. Fronczak, J. Garasic, D. Grant, R. Harrison, E. Hellstrom, F. Helsen, J.-O. Heuer, V. Hoffeld, P. Jaatinen, G. Janoshalmi, B. Holohan, N. Jungmann, T. Kadner Graziano, S. Kantara, P. Keinert, B. Lurger, M. Melcher, L. Montrasio, J. Morais Carvalho, R. Norkus, A. Orgaard, D. Orsula, G. Piazza, J.P. Pinto-Ferreira, K. Pisani Bencini, M. Porzycki, A. Rachwal, M. Reymond, P. Rubellin, V. Sajadova, P. Sprinz, M.E. Storme, T. Tofaridou, H. Vallender, F.J.A. Varona, I. Venieris, P. Viirsalu, O. Zaitsev, A. Zetko, L.G. Zidaru