Detecting Conflicts in Legal Systems

When acting in different jurisdictions (e.g. under the laws of different countries) at the same time, it can be of great value for individuals to be able to determine whether disparities among the laws of these different systems exist and allowing them to identify the consequences that may follow from these disparities. For individuals, it is typically not of interest to find all the ways in which these legal systems differ, but rather to establish whether a particular course of action may have different legal interpretations, depending on the jurisdiction. In this paper we present a formal and computational framework that, given specific scenarios (descriptions of courses of action), can automatically detect whether these scenarios could lead to different outcomes. We demonstrate our approach by means of a private international law case-study where a company drafts a contract clause after examining the consequences in the available jurisdictions.