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Today, there is a growing number of policy-based compulsory provisions in national legal systems. Regarding the severe impacts of those specific rules on private legal relationships, a specific concept which is termed «overriding mandatory rules» has been developed in the modern Private International Law and those rules started to play an important role in national codes and European Union llegal instruments. This Study, by addressing the question of how third country overriding mandatory rules are treated under Swiss, Turkish and EU law, offers an analytical comparison of those three legal systems with regard to their treatment of third country overriding mandatory rules both in contractual and delictual relationships. The book is going to be a guidance of treatment of overriding mandatory rules for both scholars and practitioners.
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Application of third country overriding mandatory rules - analytical comparison of Swiss, Turkish and EU law, Belkis Vural Çelenk
- Langue
- Année de publication
- 2018
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