The common law jurisprudence of the conflict of laws / Sarah McKibbin, Anthony Kennedy.

Oxford : Hart Publishing, 2023.

1st edition

201601

Conflict of laws -- English-speaking countries.

1. Brook v Brook: rethinking marriage choice of law

2. The mixed blessing of Vita Food products: the impact and influence of the privy council's decision

3. Erie Railroad Company v Tompkins in a private international law context

4. Good stock? The enduring influence of the 'proper law' rule in Bonython v Commonwealth of Australia

5. M/S Bremen v Zapata Off -Shore Company: US common law affirmation of party autonomy

6. Lucy's argument: The spycatcher case in Australia

7. Conflicts and public law concerns: a new way of conceiving the conflict of laws: Morguard Investments Ltd v De Savoye

8. Tolofson v Jensen: reframing the Canadian common law choice of law rule for torts

9. The limits of our tolerance for Acts of foreign states: the legacy of Kuwait Airways (Nos 4 and 5)

10. Bid Industrial Holdings (Pty) Ltd v Strang and Another (Minister of Justice and Constitutional Development, Third Party): an analysis

11. Re Flightlease and common law judgment-recognition in Ireland

12. Vizcaya Partners Limited v Picard: implications for the recognition and enforcement of foreign judgments at common law and beyond.

This book presents a collection of leading common law cases in private international law ranging from the 18th to the 21st century. The cases traverse issues of jurisdiction, choice of law and the recognition and enforcement of foreign judgments. Questions of marital validity, domicile, foreign immovable property and choice of law in contract are just some of the topics that this collection examines. The 'unusual factual situations' of some 18th- and 19th-century English cases also reveal compelling human interest stories and political controversies worthy of further exploration. Drawing on a diverse team of contributors, this edited collection showcases the research of eminent conflicts scholars together with emerging scholars from the United Kingdom, Australia, Canada, Ireland and South Africa. - Publisher's website.

Includes bibliographical references and index.

9781509954278

xxxii, 260 pages ; 24 cm