Blogs about: Applicable Law

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Wahl AG in Unamar: national gold-plating of Union law does qualify as lois de police under the Rome Convention

Geert Van Calster wrote 1 week ago: I flagged earlier that regardless of the outcome for the Unamar case itself, an important considerat … more →

Tags: Conflict of Laws /Private international law, Harmonisation, ECJ, CJEU, Rome I Regulation, Lois de police, AR/Blade, Case C-184/12, Unamar

Applicable law and arbitration clauses - lex arbitri, lex curia, lex contractus - The English view in Sulamerica

Geert Van Calster wrote 2 weeks ago: Preferring to settle issues by arbitration (often preceded by mediation) continues to be a preferred … more →

Tags: Conflict of Laws /Private international law, Arbitration Law, commercial arbitration'

Wahl AG offers substantive criteria for 'closer connection' test for contracts of employment

Geert Van Calster wrote 1 month ago: In his Opinion in Schlecker v Boedeker, Wahl AG offers a number of substantive criteria for national … more →

Tags: Conflict of Laws /Private international law, Court of Justice, protected categories, ECJ, CJEU, Regulation 593/2008, European Court of Justice, Rome I, Employment

What law applies to the piercing of the corporate veil? The Supreme Court (not) in VTB.

Geert Van Calster wrote 2 months ago: In VTB [[2013] UKSC 5] , the Supreme Court of the United Kingdom revisits in signature erudite fashi … more →

Tags: Conflict of Laws /Private international law, Corporate Veil, forum connogati, Forum Non Conveniens, misrepresentation, piercing the corporate veil, shell, Supreme Court, Tort

Sulamerica applied in Arsanovia - Expressly excluding parts of a national law may lead to that law being lex arbitri.

Geert Van Calster wrote 2 months ago: In Arsanovia, the High Court applied the Sulamerica test for identifying the lex arbitri (see here f … more →

Tags: Conflict of Laws /Private international law, Arbitration, Arsanovia, High Court, iaca, lex arbitri, Lex causae, sulamerica

Suing in a big happy EU family

mdb consultancy wrote 3 months ago: So many laws!! Suing in a big happy EU family. You do work for English company ABC Limited in Englan … more →

Tags: Drafting, Jurisdiction, Contract, INTERNATIONAL, court

The Laws Governing an Arbitration4 comments

Shaun Lee wrote 11 months ago: It is very common for an international commercial arbitration to involve parties from two (or more) … more →

Tags: Arbitration, ASEAN, arbitration, Enforceability, singapore international arbitration, Singapore Arbitration, proper law, lex arbitri, proper law of arbitration

International Review of the Red Cross

Katharine Fortin wrote 11 months ago: The International Review of the Red Cross has dedicated its last two editions to the theme of armed … more →

Tags: Journal Article, organisation, Economic dimensions of armed groups, Compliance, Equality, detention, use of force, Codes of Conduct, engagement

Review of International Tribunal Decisions for the week of February 27, 2012

Joseph William Davids wrote 1 year ago: The week the International Criminal Tribunal for the Ex-Yugoslavia (ICTY) issued a decision on the r … more →

Tags: Weekly Review, International Criminal Tribunal, icc, international criminal law, International Criminal Court, International Criminal Tribunal for the Former Yugoslav, International Criminal Tribunal for Rwanda, ICTY, ICTR

Strategic Arbitration: Is Arbitration better for you than a battle in the court?

abhyu5u wrote 3 years ago: If you are in a business, or if you deal in property, or maybe just that you are an employer or empl … more →

Tags: Arbitration, suitability, appointing arbitrator, Strategy, venue


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