Unilateralism in European Private International Law
MAX PLANCK ENCYCLOPEDIA OF EUROPEAN PRIVATE LAW, Jürgen Basedow, Klaus Hopt & Reinhard Zimmermann, eds., Oxford University Press, 2012
8 Pages Posted: 23 Jan 2012
Date Written: January 21, 2012
The articles deals with unilateralism and multilateralism in European Private International Law. It provides an overview of the historical development and looks at trends in current national and international legal systems. It argues that, in Europe, multilateralism has by and large prevailed both on the level of national and on the level of international (European) law. However, it also shows that unilateralism plays an important role in international economic law and secondary European Union law.
Keywords: Unilateralism, Multilateralism, Secondary Union Law, International Economic Law, Overriding Mandatory Law, Carl Friedrich von Savigny, Brainerd Currie, Conflict of Laws, Private International Law
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