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This is the third edition of a book formerly published by Lloyds of London Press under the title International Commercial Disputes. It is concerned with how commercial disputes which have connections with more than one country are dealt with by the English
This is the third edition of a book formerly published by Lloyds of London Press under the title International Commercial Disputes. It is concerned with how commercial disputes which have connections with more than one country are dealt with by the English courts. Much of the law which provides the framework for the resolution of such disputes is derived from international instruments, as a consequence of which English law is very similar to or the same as the law of other countries in Europe and beyond. The work comprises three parts. The first part considers the jurisdiction of the English courts and the recognition and enforcement in England of judgments granted by the courts of other countries. This part of the work, which involves analysis of both the Brussels regime (comprising the Brussels I Regulation, the Brussels Convention and the Lugano Convention) and the so-called traditional rules, includes chapters dealing with jurisdiction in personam and in rem, antisuit injunctions and provisional measures. The works second part focuses on the rules which determine whether English law or the law of another country is applicable to a given situation.
The part includes a discussion of choice of law in contract and tort, foreign currency obligations and proof of foreign law. The third part of the work is an analysis of legal aspects of international commercial arbitration. In particular, this part examines: the powers of the English courts to support or supervise an arbitration; the effect of an arbitration agreement on the jurisdiction of the English courts; the law which governs an arbitration agreement and the parties dispute; and the recognition and enforcement of foreign arbitration awards.
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