Foreign Law in Civil Litigation: A Comparative and Functional Analysis (Oxford Private International Law Series)
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Foreign Law in Civil Litigation: A Comparative and Functional Analysis (Oxford Private International Law Series)
This work provides an analysis of how foreign law should be pleaded and dealt with in the litigation process of another country. What weight should the trial court give to the relevant foreign law, and how should it decide what the foreign law actually is? The way foreign law is procedurally treated in court indicates to a certain extent the degree of tolerance of a legal system towards foreign ideas. The book compares how these issues are handled in different national systems, with particular focus upon civil litigation rules in the US, UK, France, Germany, the Netherlands and Belgium.