Download This PaperReciprocal Comity
19 Pages Posted: 5 Mar 2018
Date Written: Summer 2011
Abstract
In this article, Professor Janger seeks to define the principle of "universalism" in cross-border bankruptcy cases, as described by Lord Leonard Hoffman in his opinion in the HIH case (McGrath v. Riddell). Professor Janger compares Hoffman's view to Jay Westbrook's principle of "modified universalism" and to the competing approach of "universal proceduralism."
Keywords: bankruptcy, International bankruptcy, legal harmonization
Suggested Citation: Suggested Citation
Janger, Edward J., Reciprocal Comity (Summer 2011). 46 Tex. Int'l L. J. 441 (2011), Available at SSRN: https://ssrn.com/abstract=3129826
Edward J. Janger (Contact Author)
Brooklyn Law School ( email )
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