Unilateralism in European Private International Law

MAX PLANCK ENCYCLOPEDIA OF EUROPEAN PRIVATE LAW, Jürgen Basedow, Klaus Hopt & Reinhard Zimmermann, eds., Oxford University Press, 2012

8 Pages Posted: 23 Jan 2012

See all articles by Giesela Ruhl

Giesela Ruhl

Humboldt University of Berlin

Date Written: January 21, 2012

Abstract

The articles deals with unilateralism and multilateralism in European Private International Law. It provides an overview of the historical development and looks at trends in current national and international legal systems. It argues that, in Europe, multilateralism has by and large prevailed both on the level of national and on the level of international (European) law. However, it also shows that unilateralism plays an important role in international economic law and secondary European Union law.

Keywords: Unilateralism, Multilateralism, Secondary Union Law, International Economic Law, Overriding Mandatory Law, Carl Friedrich von Savigny, Brainerd Currie, Conflict of Laws, Private International Law

Suggested Citation

Ruhl, Giesela, Unilateralism in European Private International Law (January 21, 2012). MAX PLANCK ENCYCLOPEDIA OF EUROPEAN PRIVATE LAW, Jürgen Basedow, Klaus Hopt & Reinhard Zimmermann, eds., Oxford University Press, 2012, Available at SSRN: https://ssrn.com/abstract=1989540

Giesela Ruhl (Contact Author)

Humboldt University of Berlin ( email )

Unter den Linden 9
Berlin, D-10099
Germany

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