Edward Elgar Publishing Public Policy and Private International Law: A Comparative Guide (Elgar Comparative Guides)

The public policy exception in private international law is designed to provide a national backstop in the application of foreign laws. This book provides detailed and practical comparative coverage of the use of public policy in the context of private international law across a number of important jurisdictions spanning three continents. As well as explaining the basic theoretical framework of the public policy exception in private international law, the book drills down into the practical application of such rules, giving an overview of these jurisdictions’ legal and policy stances on current issues including: punitive damages, surrogacy, same-sex marriage, gender-based discrimination, Islamic law, and adoption to name a few. This approach serves to highlight both the differences and the similarities in approach. Key Features: The first book to give a detailed practical treatment of the public policy exception in private international law Coverage of 16 key jurisdictions Two cross-cutting chapters that work through the comparative elements Chapters written by experts in their respective jurisdictions The book is the first to provide systematic jurisdictional coverage of the public policy exception and will be of immense value to notaries and practising lawyers navigating their way through this complex interaction. Academics and policy makers with a special interest in private international law will also find this an excellent platform for further research.