Place of Performance: A Comparative Analysis
Chukwuma Samuel Adesina Okoli
This book provides an unprecedented analysis on the place of performance. The central theme is that the place of performance is of considerable significance as a connecting factor in international commercial contracts. This book challenges and questions the approach of the European legislator for not explicitly giving special significance to the place of performance in determining the applicable law in the absence of choice for commercial contracts. It also contains, inter alia, an analogy to matters of foreign country mandatory rules, and the coherence between jurisdiction and choice of law. It concludes by proposing a revised Article 4 of Rome I Regulation, which could be used as an international solution by legislators, judges, arbitrators and other stakeholders who wish to reform their choice of law rules.
Volume 27 in the series Studies in Private International Law
Volume 27 in the series Studies in Private International Law
年:
2020
出版社:
Hart Publishing
语言:
english
ISBN 10:
1509936238
ISBN 13:
9781509936236
系列:
Studies in Private International Law
文件:
PDF, 3.08 MB
IPFS:
,
english, 2020