- Title Pages
- Foreword
- Contributors
- Introduction: Private International Law and Cosmopolitan Integration
-
1 Private International Law as an Ethic of Responsivity -
2 Embracing Diversity – The Role of the Hague Conference in the Creation of Universal Instruments -
3 Managing Diversity in Cross-border Succession Problems: A British Perspective -
4 Cross-border Family Issues in the EU: Multiplicity of Instruments, Inconsistencies and Problems of Coordination -
5 Non-uniform Application of European Union Private International Law -
6 On Private International Law, the EU and Brexit -
7 International Judicial Cooperation as the Architecture of Engagement -
8 Judicial Cooperation: Resolving the Differing Approaches -
9 Judicial Cooperation in South America: A Regional Perspective -
10 Civil Judicial Cooperation: A Scottish Experience -
11 The Judgments Project of the Hague Conference on Private International Law: A Way Forward for a Long-awaited Solution -
12 Integrating Legal Approaches to Migration -
13 Labour Migration and Private International Law -
14 E-commerce and Consumer Protection in Integrated Markets -
15 Protection of the Individual in Recent Private International Law Codification in Latin America -
16 The Challenges of the New Social and Scientific Realities in Private International Family Law – The Latin American Experience -
17 The Key Role of Judges in the Development of Private International Law: Lessons Learned from the Work of the Hague Conference on Private International Law -
18 Private International Law and International Commercial Arbitration – A Dialogue about the Usefulness and Awareness of the Former for the Latter -
19 Demystifying Private International Law for International Commercial Contracts -
20 Public Policy in Private International Law: Guardian or Barrier? -
21 Bridging and Balancing: Diversity and Integration in Private International Law - Index
Non-uniform Application of European Union Private International Law
Non-uniform Application of European Union Private International Law
- Chapter:
- (p.83) 5 Non-uniform Application of European Union Private International Law
- Source:
- Diversity and Integration in Private International Law
- Author(s):
Katarina Trimmings
Burcu Yüksel
- Publisher:
- Edinburgh University Press
This chapter draws on the findings of an EU-funded project titled (‘Cross-Border Litigation in Europe: Private International Law Legislative Framework, National Courts and the Court of Justice of the European Union’ (EUPILLAR) and discusses concerns over the lack of uniformity in the interpretation and application of the key EU Private International Law Regulations (Brussels I Regulation, Brussels IIa Regulation, Rome I Regulation, Rome II Regulation, Maintenance Regulation) across the EU Member States. The chapter provides examples of differing interpretations and applications of the same EU private international law rules in the EU through examples from various EU Member States, analyses the reasons behind the non-uniform interpretation and application, and suggests specific ways to rectify these problems.
Keywords: EU Private International Law, EUPILLAR, Brussels I Regulation, Brussels IIa Regulation, Rome I Regulation, Rome II Regulation, Maintenance Regulation, cross-border litigation
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- Title Pages
- Foreword
- Contributors
- Introduction: Private International Law and Cosmopolitan Integration
-
1 Private International Law as an Ethic of Responsivity -
2 Embracing Diversity – The Role of the Hague Conference in the Creation of Universal Instruments -
3 Managing Diversity in Cross-border Succession Problems: A British Perspective -
4 Cross-border Family Issues in the EU: Multiplicity of Instruments, Inconsistencies and Problems of Coordination -
5 Non-uniform Application of European Union Private International Law -
6 On Private International Law, the EU and Brexit -
7 International Judicial Cooperation as the Architecture of Engagement -
8 Judicial Cooperation: Resolving the Differing Approaches -
9 Judicial Cooperation in South America: A Regional Perspective -
10 Civil Judicial Cooperation: A Scottish Experience -
11 The Judgments Project of the Hague Conference on Private International Law: A Way Forward for a Long-awaited Solution -
12 Integrating Legal Approaches to Migration -
13 Labour Migration and Private International Law -
14 E-commerce and Consumer Protection in Integrated Markets -
15 Protection of the Individual in Recent Private International Law Codification in Latin America -
16 The Challenges of the New Social and Scientific Realities in Private International Family Law – The Latin American Experience -
17 The Key Role of Judges in the Development of Private International Law: Lessons Learned from the Work of the Hague Conference on Private International Law -
18 Private International Law and International Commercial Arbitration – A Dialogue about the Usefulness and Awareness of the Former for the Latter -
19 Demystifying Private International Law for International Commercial Contracts -
20 Public Policy in Private International Law: Guardian or Barrier? -
21 Bridging and Balancing: Diversity and Integration in Private International Law - Index
