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The Operation of the Escape Clauses in the Rome Convention, Rome I Regulation and Rome II Regulation [PDF]

open access: yesJournal of Private International Law, 2012
peer reviewedThis article critically discusses the various approaches to the operation of the escape clauses in the Rome Convention, Rome I Regulation and Rome II Regulation. A proposal is made for the deletion of the doctrine of implied choice of law in
Chukwuma Samuel Adesina Okoli
exaly   +6 more sources
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