Font Size: a A A

Interest Analysis Method In Private International Law

Posted on:2007-05-10Degree:MasterType:Thesis
Country:ChinaCandidate:X ChengFull Text:PDF
GTID:2166360185493918Subject:Civil and Commercial Law
Abstract/Summary:PDF Full Text Request
Jurisprudence of Interests arose at the cross of the 19th and 20th century in Germany. Under the guide of this theory, Professor Brainerd Currie, a famous Private International Law scholar in USA, led the interest analysis method into private international law, called "the theory of governmental interest analysis". Currie's governmental interest analysis is one of the most influential modern choice-of-law theories .He advocated the analyzation of the governmental interests behind the law confliction.During the same period, famous Private International Law scholar Gerhard Kegel, a Germany Professor, took the lead in introducing Jurisprudence of Interests into private international law. But in Kegel's opinion , Private International Law should protect the interests of parties, communication and order, but not the governmental interests. This thesis summarizes the main thoughts and various comments from other scholars of Kegel's "interest theory" and Currie's theory. On the basis of these introductions, I come up with my own opinions on this issue.Under the distinctive feature and the historical evolution of private international law,...
Keywords/Search Tags:Jurisprudence of Interests, Currie's "the theory of governmental interest analysis", Kegel's "interest theory", interest analysis methord
PDF Full Text Request
Related items