Search for: "Fori v Fori"
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27 Jan 2014, 2:05 am
These techniques were not abolished, nor did they end up being replaced, in any one of the regimes, by systematic application of the lex fori, by conflict rules using as connecting factors völkisch or racial characteristics in Nazi Germany, or more simply by arbitrariness. [read post]
14 Aug 2023, 5:03 am
See Douez v Facebook, Inc [2017] 1 SCR 751. [read post]
6 Sep 2011, 3:36 am
Although the court does not refer to the process of classification, the decision attests to an enlightened lex fori approach to characterisation. [read post]
1 Feb 2021, 7:13 am
Hoge Raad 17 juli 2020, ECLI:NL:HR:2020:1280, NIPR 2020, 487 (V Marine Fuels/Dexhon c.s.) / p. 748-759 This article discusses the judgment of the Dutch Supreme Court dated 17 July 2020, ECLI:NL:HR:2020:1280. [read post]
10 Nov 2020, 12:08 pm
Volkswagen Aktiengesellschaft v Schlunk decided by the Supreme Court of the US and Segers and Rufa BV v. [read post]
10 May 2012, 4:02 am
The author uses the Consumer Credit Act 1974 and the House of Lord’s decision in OFT v Lloyds to illustrate the argument. [read post]
1 Feb 2014, 8:15 pm
English law applies the lex fori exclusively to determine whether an obligation exists which the court has jurisdiction to enforce. [read post]
1 Jul 2017, 9:16 pm
Contents include: Angela Del Vecchio, Cenni Introduttivi Sulla Tutela Degli Investimenti Stranieri Nel Diritto Internazionale E Nel Diritto Dell’unione Europea
Maria Rosaria Mauro, Conflitti Di Competenza E Coordinamento Tra Fori Nel Diritto Internazionale Degli Investimenti: Contract Claims v. [read post]
27 May 2016, 7:00 am
Legal Issue The Foreign Limitation Periods Act 1984 provides that English courts should apply the law of limitation of the place whose law is being applied to the substantive legal issues being decided in a case (aka the lex causae) rather than the law of the England (aka the lex fori). [read post]
15 May 2014, 11:40 am
On the principle of the matter, he stated at 111:In my judgment this reasoning [from Rohm & Haas] is persuasive, and it is supported by the subsequent judgment of the Court of Appeal in Virgin v Premium. [read post]
9 Jul 2012, 4:09 pm
As the Court explained in United States v. [read post]
15 Aug 2018, 1:33 am
According to the court, this question was to be answered by the lex fori. [read post]
4 Feb 2010, 12:58 pm
Necessidad de reforma Cecilia Fresnedo de Aguirre, La nueva ley uruguaya de concursos y reorganización empresarial : un importante avance en sintonía con los principios internacionales en la materia Adriana V. [read post]
12 Dec 2011, 3:28 am
The pioneers were FORIS, who are a listed stand-alone entity. [read post]
26 Jun 2012, 12:49 am
The mistake to be lamented presently is the High Court decision in Yukos Capital Sarl v OJSC Rosneft Oil Co that a Dutch judgment gave rise to an issue estoppel in English proceedings, precluding a party from disputing as a fact the partiality and dependence of the Russian judiciary. [read post]
6 May 2009, 7:25 am
Hanjin Oakland Case: Carriage aboard the M/V “Hanjin Oakland” of four boxes with machine tools from Taiwan to Rotterdam. [read post]
15 May 2023, 9:28 am
Phipps wrote that in Auld v. [read post]
12 Nov 2020, 6:35 am
Between 9 December and 12 December 2019, the UK Supreme Court heard the joint appeals in the matter of The Law Debenture Trust Corporation plc v Ukraine. [read post]
Foreign Judgments: The Limits of Transnational Issue Estoppel, Reciprocity, and Transnational Comity
26 May 2021, 8:40 pm
It accepted that issue estoppel raises a question of lex fori procedure, and that as a starting point, the same principles of issue estoppel apply whether the previous judgment is a local or foreign one. [read post]
16 Nov 2011, 7:48 am
fori? [read post]
