1 online resource (xii, 333 p.) : ill.
9781474201391 online 9781849462686 hardback 9781782253723 electronic book 9781782253716 PDF
Studies in private international law ; v. 14.
"This extensive comparative study of the three most important judgment recognition and enforcement (JRE) regimes focuses on what lessons China can draw from the US and the EU in developing a multilateral JRE arrangement for mainland China, Hong Kong, and Macao."--Jacket. "Judgment recognition and enforcement (JRE) between US sister states, between EU member states, and between Mainland China, Hong Kong, and Macao, are in the category of "interregional JRE." This article focuses on what lessons China may draw from the US and the EU to develop its interregional JRE laws. It first discusses the status quo of the interregional JRE in China. Then it explores how the interregional economic integration demands the establishment of a multilateral interregional JRE arrangement in China. Finally it points out the four most crucial challenges in developing this arrangement: the challenge relating to the socialist characters of Mainland law, conflicts between civil and common laws, weak mutual trust, and the lack of a court of final review for cases from all the three regions. It proposes solutions to each challenge by comparative studies with the US and the EU interregional JRE laws"--Bloomsbury Publishing.
Based on the author's thesis (S.J.D.)--Duke University, School of Law.
Bibliography, etc. Note
Includes bibliographical references and index.
Formatted Contents Note
Scholarly achievements in Chinese interregional conflict of laws The existing JRE system among mainland China, Hong Kong and Macao Three serious macro challenges and their solutions Selected rules of the proposed multilateral JRE arrangement Implementation of the proposed multilateral JRE arrangement.