This book offers a comprehensive study of the prerequisites, effectiveness, and enforcement of exclusive jurisdiction and arbitration agreements in international dispute resolution. It examines whether jurisdiction and arbitration clauses have identical effects in private international law and whether they have been or should be given the same treatment by most countries in the world. By comparing the treatment of these clauses in the US, China, UK and EU, Zheng Sophia Tang demonstrates how, in practice, exclusive jurisdiction and arbitration agreements are enforced.
This book offers a comprehensive study of the prerequisites, effectiveness, and enforcement of exclusive jurisdiction and arbitration agreements in international dispute resolution. It examines whether jurisdiction and arbitration clauses have identical effects in private international law and whether they have been or should be given the same treatment by most countries in the world. By comparing the treatment of these clauses in the US, China, UK and EU, Zheng Sophia Tang demonstrates how, in practice, exclusive jurisdiction and arbitration agreements are enforced.
Zheng Sophia Tang is a Chair at the Newcastle University Law School, UK.
Inhaltsangabe
1. Procedural Autonomy in International Commerce 2. Prerequisites: Contractual Issues 3. Preliminary Requirements: Which Forum Decides? 4. Enforceability of Jurisdiction and Arbitration Agreements 5. Supporting Party Autonomy: LisPendens, Forum Non Conveniens and Anti-Suit/Anti-Arbitration Injunctions 6. Conflicts of Jurisdiction and Party Autonomy in Europe 7. The Future of the Hague Choice of Court Convention: A Litigating Counterpart of the New York Convention?
1. Procedural Autonomy in International Commerce 2. Prerequisites: Contractual Issues 3. Preliminary Requirements: Which Forum Decides? 4. Enforceability of Jurisdiction and Arbitration Agreements 5. Supporting Party Autonomy: LisPendens, Forum Non Conveniens and Anti-Suit/Anti-Arbitration Injunctions 6. Conflicts of Jurisdiction and Party Autonomy in Europe 7. The Future of the Hague Choice of Court Convention: A Litigating Counterpart of the New York Convention?
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