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Comparative Interpretation Standards in Uniform International Law [PDF]
International Perspectives on Education and Society, 2015 Abstract In this chapter, the author offers a horizontal comparison of interpretation standards contained in international legal instruments of different origin. These legal instruments range from international treaties to model laws. They also originate from different law makers such as the United Nations or individual states as well
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Uniform Law Review, 2022 Abstract In an effort to assist in the better understanding and implementation of the UNCITRAL Model Law on Secured Transactions (including its provisions on the registration of notices with respect to security interests) and the Model Inter-American Law on Secured Transactions with the Model Inter-American Registry Regulations, this ...
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Comparing Matrimonial Laws in India and Vietnam: Is a Uniform Civil Code Necessary?
Vietnamese Journal of Legal Sciences, 2022 Abstract India secured its independence from the British rule in 1947. Vietnam eliminated the presence of foreign military forces in 1975. Both countries have faced adversity through subjugation. The similarity does not end here. The family unit in both nations is given primary precedence and importance, as it is considered to be the ...
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European Business Law Review, 2018 Our article is based on a fresh dialogue between two colleagues of public international law and comparative private law. We question whether the standard of interpretation of uniform private conventions is, or should be, identified and shaped under the two scholarships. In particular, we aim to answer three main research questions.
Lorenza Mola, Cristina Poncibò
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Promoting Uniformity: A Comparative Review of J Honnold and H Flechtner, Uniform Law for International Sales under the 1980 United Nations Convention and P Schlechtriem and I Schwenzer, Commentary on the UN Convention on the International Sale of Goods [PDF]
Journal of Private International Law, 2011 Academic commentaries on the United Nations Convention on Contracts for the International Sale of Goods (hereafter CISG) arguably perform a more important role than most legal academic texts. That role is essentially to assist in an international, uniform interpretation of the CISG. This becomes important because the CISG is an international convention
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International and Comparative Law Quarterly, 1989 THIS article compares the provisions of the UN Convention on Contracts for the International Sale of Goods (Vienna, 1980--"the UN Sales Convention")' to those of the Uniform Law on the International Sale of Goods (ULIS) and the Uniform Law on the Formation of Contracts of Sale (ULF) (Hague Conventions, 1964).2 The ULIS and the ULF served as the ...
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Mizan Law Review, 2017 Various countries have reformed their secured transaction laws recognizing the significance of modern secured transactions law in enhancing access to credit and economic development. Ethiopia has not undertaken comprehensive secured transactions law reform, despite the demonstrable mismatch between the legal regime governing security interests and the ...
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The Impact of Uniform Civil Code on Personal Laws in India: A Comparative Analysis
Abstract: The Uniform Civil Code (UCC) has been a subject of intense debate in India, as it seeks to replace personal laws based on religion with a common set of civil laws governing marriage, divorce, inheritance, and adoption. This study examines the impact of the UCC on personal laws in India through a comparative analysis of different legal ...
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پژوهش های حقوق تطبیقیThe Business-Judgment Rule can be defined as a doctrine that protects directors from personal responsibilities if they act in good faith, with due care and within the framework of their powers and duties, including the care and fiduciary duty. Accordingly to this research, with a comparative study of the American, England, Australian and Iranian law by
hamid Abhary +2 more
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پژوهش های حقوق تطبیقیAlthough the development of the use of information technology in commercial transactions especially in international type, is economically favorable, but it has not been widely accepted by stakeholders. This is also true regarding the electronic substitutes for possessable trade documents, such as bills of lading and insurance policies.
Mostafa Elsan +1 more
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