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Englischer ordre public gegen ausländische Verjährungsvorschriften

Abstract:

Significantly different from the EU conflict-of-laws regime of the Rome I and II Regulations, the British autonomous regime provides for a special public policy exception in the Foreign Limitation Periods Act 1984, whose design and application are critically examined in this paper. When English courts employ this Act, which could become particularly relevant after the Brexit transition period, the public policy exception not only has a lower threshold and lets undue hardship suffice, it also ...

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Publication status:
Published
Peer review status:
Peer reviewed

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Institution:
University of Oxford
Division:
SSD
Department:
Law
Sub department:
Law Faculty
Oxford college:
St Hilda's College
Role:
Author
Publisher:
Gieseking Verlag Publisher's website
Journal:
IPRax Journal website
Volume:
41
Issue:
3
Pages:
298-304
Publication date:
2021-05-01
Acceptance date:
2020-08-18
ISSN:
0720-6585
Language:
German
Keywords:
Pubs id:
1168994
Local pid:
pubs:1168994
Deposit date:
2021-03-23

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