JUSTIFYING CONCURRENT CLAIMS IN PRIVATE INTERNATIONAL LAW

نویسندگان

چکیده

Abstract Can claimants choose between contract and tort claims arising on the same facts with different jurisdictional and/or choice-of-law consequences? While domestic legal systems generally recognise concurrent liability, commentators object that its extension to private international law would be unprincipled threaten field's values. This, however, contrasts position in common under EU Regulations, where are recognised only narrow limits. This article justifies law, arguing premises supporting liability exist no field-unique concerns foreclose it.

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ژورنال

عنوان ژورنال: Cambridge Law Journal

سال: 2023

ISSN: ['0008-1973', '1469-2139']

DOI: https://doi.org/10.1017/s0008197322000897