BOOK REVIEW: Commercial Issues in Private International Law: A Common Law Perspective (Studies in Private International Law)

摘要

First, the reviewer would like to mention that since he is a doctor in civil law, with an MCL from Columbia University, but has been trained in common law principles, his opinions are based on the commercial issues he has practised for many years on the intersection of commercial law and international private law for international and local clients. This is a challenging task since the common law as developed in England and implanted on the United States is one thing, but adaptation of the common law to Australia, Canada, India, New Zealand and Singapore is another matter, since those jurisdictions have adapted the common law for their own purposes. It is to be noted that England, as part of the European Union, was obliged to respect European decisions (directives or mandatory judgments), like any member of the EU, except those excluded matters such as its own currency, the aforementioned common law countries continued to follow the precedents of the English courts, despite the fact that all of them enacted their own statutes.