... causing damage in a situation of necessity exemplifies the idea of legal responsibility, and thus helps in better understanding the law of non-contractual obligations. Methodologically, the article combines historical arguments derived from the late scholastic theory of restitution with a comparative...

... the requirement of good faith and its role in the formation of contracts; Part III is concerned with contractual obligations; Part IV examines breach of contract and remedial issues....

... 7.01 The choice of law rules for contractual obligations under Singapore law closely mirror the equivalent choice of law rules under the English common law. Central to contract choice of law is the proper law of the contract. However, it is by no means the case that every issue that may arise...

...Parties to litigation Hague Evidence Convention Insolvency Preserving assets Anti-suit injunctions and jurisdiction Jurisdiction under the Lugano Convention Jurisdiction under the Brussels I Regulation Applicable law Non-contractual obligations Jurisdiction clauses 5.01 The forms...

...Declarations Contractual agreements on jurisdiction Non-contractual obligations Collective redress procedures 15.01 Anti-suit injunctions, and claims for damages, are not the only available tool for resolving or shaping conflicts of jurisdiction. This chapter considers alternative remedies...

...Rome Convention Rome I Regulation and choice of law Applicable law Interpretation and trade practices Damages Scope of the law applicable under the Rome II Regulation Tort/delict Applicable law to non-contractual obligations Unjust enrichment Unfair competition 1.01 The EC...

...Applicable law Choice of law clauses Rome Convention Breach of contract Tort/delict Applicable law to non-contractual obligations Culpa in Contrahendo Industrial action Jurisdiction under the Brussels I Regulation Equitable obligations Article 4 General rule 1. Unless otherwise...

...Applicable law Breach of contract Calculation of damages Applicable law to non-contractual obligations Unfair competition Scope of the law applicable under the Rome II Regulation Forum shopping and disputes Jurisdiction under the Brussels I Regulation Article 6 Unfair competition and acts...

...Applicable law Exemption from liability Applicable law to non-contractual obligations Environmental damage Scope of the law applicable under the Rome II Regulation Recognition and enforcement of foreign judgments – Brussels and Lugano Conventions Non-contractual obligations Article 7...

...Scope of applicable law Intangibles as goods Applicable law and intellectual property Infringement of IP rights and jurisdiction Remedies Applicable law to non-contractual obligations Scope of the law applicable under the Rome II Regulation Article 8 Infringement of intellectual property...

...Limitation of liability Rome Convention Rome I Regulation and choice of law Scope of applicable law Punitive damages Rules of conduct and non-contractual obligations Applicable law to non-contractual obligations Scope of the law applicable under the Rome II Regulation Public policy...

... to the claim, but may be between each of them and a third person. N-8-1 In footnote 5, add: See also Case C-64/17, Saey Home & Garden, ECLI:EU:C:2018:173, at paragraph 34 of the judgment. Contractual agreements on jurisdiction Equitable obligations Non-contractual obligations...

... fundamental implications for the approach to be taken. In the case of EU legislation, the Court of Justice has consistently stressed the need for national courts to avoid a narrow domestic approach to construction and adopt a broad autonomous EU approach. Contractual obligations Employment contracts...

...-contractual claims. Choice of law clauses Jurisdictional agreements and the common law Express choice Implied choice Contractual obligations Employment contracts Jurisdiction over contracts of employment Applicable law to non-contractual obligations 6.01 Once a court or tribunal has determined...

... in international cases. Choice of court and jurisdictional agreements Choice of law Contractual obligations Employment contracts Jurisdiction over contracts of employment 9.01 The most important areas in practice where claims are regularly made by employers against employees is in the context of post...

... connection test emerges as the optimal conflict of laws rule for international commercial arbitration. Choice of law clauses Stateless applicable law Unidroit Principles and choice of law Contractual obligations Legal risk in multi-state transactions Applicable law in multi-state transactions...

... Icelandic legislation. The legislative act which applies to contractual obligations in the field of private international law in Iceland is Act No 43/2000 on the law applicable to contractual obligations. There are no other acts that explicitly aim to address choice of law issues other than Act No 43/2000...

...Jurisdiction under the Brussels I Regulation Article 23 Jurisdiction and the English courts Injunctions to restrain proceedings Recognition and enforcement of foreign judgments – Brussels and Lugano Conventions Parties to litigation Burden of proof Validity of contract Contractual...