Global ETD Search
Search theses and dissertations gathered from participating repositories worldwide. Every result links back to the library that holds it. No account is needed.
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Showing 1 to 11 of 11 for “"Choice of law"”.
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Choice of law in respect of agency relationships in the European Union and the United Arab Emirates
… and the contractor. Differences between various laws exist both in the substantive rules and the choice of law rules applicable to these relationships. This thesis addresses these choice of law problems, with reference to English law, the Rome I Regulation, the Hague Convention 1978, and the UAE …
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Choice of Law in respect of contracts in the United Arab Emirates and the European Union; and related aspects of Private International Law in relation to the Dubai International Financial Centre
Private international law applies to cases governed by private law which involve factual connections with several countries. A major issue governed by private international law is the question of which country’s law should be applied to determine the merits of a dispute. This thesis focuses on …
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The law applicable to contractual obligations in consumer contracts of adhesion in Ghana
This thesis argues for the inclusion of adequate choice of law rules for consumer adhesion contracts to ensure suitable protection measures for weaker parties in Ghana. To this end, the research seeks to add to existing literature by engaging in a comparative study of the legal development of …
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A comparative study of the fundamental juridical nature, classification and private law enforcement of jurisdiction and choice of law agreements in the English Common Law of Conflict of Laws, the European Union Private International Law Regime and the Hague Convention on Choice of Court Agreements
During the course of this PhD thesis, it will be argued that it is misconceived to think of jurisdiction and choice of law agreements as unilaterally enforced domestic private law obligations within an English 'dispute resolution' paradigm because multilateral private international law rules are …
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Determining the proper law of arbitration agreements
This thesis examines the proper law of arbitration agreements, with particular focus on English law following the enactment of the Arbitration Act 2025. The central problem arises where parties choose the law governing their main contract and the seat of arbitration, but fail expressly to choose …
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Domestic Courts and Global Governance: the Politics of Private International Law
… and foreign parties have filed more than 100,000 lawsuits in U.S. federal courts asking for adjudication of disputes arising from transnational activity. These lawsuits raise a fundamental question of global governance: Who governs? Should the United States assert its authority to adjudicate a …
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Teismingumas, taikytina teisė ir įrodinėjimas civilinėse bylose dėl neleistino informacijos skelbimo internete: galimybės ir problemos /
… The first two which fall into the category of International Private Law are the assertion of judicial jurisdiction and choice of applicable law in civil cases with a foreign element, which are related to unallowable posting on the Internet, and third one is the burden of proof which falls …
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THE SCOPE OF THE LAW APPLICABLE TO COMPANIES IN THE EU.
Despite the crucial role of corporate mobility in ensuring the proper functioning of the internal market, and although Articles 49 and 54 of the Treaty on the Functioning of the European Union expressly recognize the freedom of establishment for certain – albeit not all – legal persons, the …
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From Conflict of Laws to Global Justice
At the beginning of the 21st Century, conflict-of-laws theory lies in tatters. The determination of the applicable law could hardly be more disputed and insecure. At the same time, globalization requires a strong basis on which legal systems can be coordinated. It is therefore high time to …
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Does Cyberspace outdate Jurisdictional Defamation Laws?
Cyberspace produces friction when the law is implemented by domestic courts using 'state-laws'. These laws are based on a ‘physical presence’ of an individual within the territory. It elevates conflicts relating to cyberspace jurisdiction. This research examines private international law …
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A Vision for the Future of Private International Law in the States of the Gulf Cooperation Council (GCC): Why is it Necessary for the GCC to Move Towards Private International Law Harmonisation?
The Gulf Cooperation Council (GCC), composed of the six States of the Gulf (United Arab Emirates, Kingdom of Bahrain, Kingdom of Saudi Arabia, Sultanate of Oman, State of Qatar and State of Kuwait), is striving to enhance the Gulf’s regional integration in various political, security, economic and …