French Civil Liability in Comparative Perspective, Jean-Sebastien Borghetti, Simon Whittaker
Автор: Alexandra Braun, Anne R?thel Название: Passing Wealth on Death: Will-Substitutes in Comparative Perspective ISBN: 184946698X ISBN-13(EAN): 9781849466981 Издательство: Bloomsbury Academic Рейтинг: Цена: 15840.00 р. Наличие на складе: Есть у поставщика Поставка под заказ.
Описание: Wealth can be transferred on death in a number of different ways, most commonly by will. Yet a person can also use a variety of other means to benefit someone on death. Examples include donationes mortiscausa, joint tenancies, trusts, life-insurance contracts and nominations in pension and retirement plans. In the US, these modes of transfer are grouped under the category of 'will-substitutes' and are generally treated as testamentary dispositions. Much has been written about the effect of the use of will-substitutes in the US, but little is generally known about developments in other jurisdictions. For the first time, this collection of contributions looks at will-substitutes in a comparative perspective. It examines mechanisms that pass wealth on death across a number of common law, civil law and mixed legal jurisdictions, and explores the rationale behind their use. It analyses them from different viewpoints, including those of owners of businesses, investors, as well as creditors, family members and dependants. The aims of the volume are to show the complexity and dynamics of wealth transfers on death across jurisdictions, to identify patterns between jurisdictions, and to report the attitudes towards modes of transfer in light of their utility and the potential frictions they give rise to with policies and principles underpinning current laws. (Series: Studies of the Oxford Institute of European and Comparative Law, Vol. 22) Subject: Inheritance Law, Common Law, Civil Law, Comparative Law]
Описание: Includes papers presented at a colloquium held at the Faculty of Law, National University of Singapore on 30 November and 1 December 2016 (the 250th anniversary of Carter v Boehm). -- ECIP Preface.
Автор: Helmut Koziol, Michael D. Green, Mark Lunney, Ken Oliphant, Lixin Yang Название: PRODUCT LIABILITY: Fundamental Questions in a Comparative Perspective ISBN: 3110546000 ISBN-13(EAN): 9783110546002 Издательство: Walter de Gruyter Цена: 27884.00 р. Наличие на складе: Есть у поставщика Поставка под заказ.
Описание:
Where products develop ever more rapidly, the law may face difficulties in responding accordingly to new security threats which may arise. In the field of product liability, an extraordinary need for legal development has thus been perceived, with legislators and judges feeling compelled to find new solutions and to look across borders for these. In the detailed reports in this book, the World Tort Law Society proves that it is in an ideal position to examine the most significant concepts. The report on North America studies the special regime for product liability from its origin in the case law of the US; the European report is centred around the EU Product Liability Directive with its merits and faults; and the influence of these two systems as well as new answers are shown in the reports on Asia, Russia and four key jurisdictions in the rest of the world. Similar questions are discussed worldwide: How can a strict liability regime for products be justified, and can it be justified in all cases? How does the special regime relate to general rules of tort law? Should services be subject to a similar regime? The Members of the Society seek to provoke thought for solutions to these pervasive problems. In this spirit, the volume's comparative conclusions invite discussion, and the book includes four responses to that call from eminent tort lawyers from different legal backgrounds.
This volume provides a holistic presentation of the reality of constitutional change in 18 countries (the 15 old EU member states, Canada, Switzerland and the USA). The essays offer analysis on formal and informal constitutional amendment bringing forth the overall picture of the parallel paths constitutional change follows, in correlation to what the constitution means and how constitutional law works. To capture the patterns of constitutional change, multi-faceted parameters are explored such as the interrelations between form of government, party system, and constitutional amendment; the interplay between constitutional change and the system of constitutionality review; the role of the people, civil society, and experts in constitutional change; and the influence of international and European law and jurisprudence on constitutional reform and evolution. In the extensive final, comparative chapter, key features of each country's amendment procedures are epitomized and the mechanisms of constitutional change are explained on the basis of introducing five distinct models of constitutional change. The concept of constitutional rigidity is re-approached and broken down to a set of factual and institutional rigidities. The classification of countries within models, in accordance with the way in which operative amending mechanisms connect, leads to a succinct portrayal of different modes of constitutional change engineering.
This book will prove to be an invaluable tool for approaching constitutional revision either for theoretical or for practical purposes and will be of particular interest to students and scholars of constitutional, comparative and public law.
Описание: The collapse of the Rana Plaza in Bangladesh (2013) is one of many cases to invoke critical scrutiny and moral outrage regarding the conditions under which consumer goods sold on our markets are produced elsewhere. In spite of abiding moral concerns, these goods remain popular and consumers continue to buy them. Such transactions for goods made under deplorable production conditions are usually presumed to count as ‘normal’ market transactions, ie transactions that are recognized as valid consumer-contracts under the rules of contract law. Minimum Contract Justice challenges this presumption of normality. It explores the question of how theories of justice bear on such consumer contracts; how should a society treat a transaction for a good made under deplorable conditions elsewhere? Minimum Contract Justice defends the position that a society that strives to be minimally just should not lend its power to enforce, support, or encourage transactions that are incompatible with the ability of others elsewhere to live decent human lives. As such, the book introduces a new perspective on the legal debate concerning deplorable production conditions that has settled around ideas of corporate responsibility, and the pursuit of international labour rights.
Автор: Yang, Yonghong Название: Sovereignty in china`s perspective ISBN: 3631719280 ISBN-13(EAN): 9783631719282 Издательство: Peter Lang Рейтинг: Цена: 12214.00 р. Наличие на складе: Есть у поставщика Поставка под заказ.
Описание:
This book explores China’s perspective on sovereignty. The concept of sovereignty is universal, however, the understanding of it varies in different states and due to cultural backgrounds, history or the composition of ethnic groups. In order to comprehend China’s current perspective on sovereignty, the author connects Chinese historical ideas with the current international society. She locates misunderstandings of China’s past and present which could cause misjudgment of China’s perspective on sovereignty. Hence, the author analyzes China’s imperial history concerning sovereignty and foreign policies. She surveys the cultural, political, administrative and legal roots of the ancient empires because of their great influence on its current political arrangements. In addition, the study examines the divergence between the European and Chinese understanding on human rights.
Автор: Lusina Ho, Rebecca Lee Название: Special Needs Financial Planning: A Comparative Perspective ISBN: 1108481205 ISBN-13(EAN): 9781108481205 Издательство: Cambridge Academ Рейтинг: Цена: 13147.00 р. Наличие на складе: Есть у поставщика Поставка под заказ.
Описание: Critically examines the latest developments of special needs financial planning mechanisms in Asia and the West from the perspectives of scholars and professional experts. It will appeal to scholars, students, law and policy makers and practitioners in the fields of mental disability, healthcare and elder law.
Описание: This volume explores how societies are addressing challenging questions about the relationship between expression, traditional and societal values, and the transformations introduced by new information communications technologies, and seeks to identify alternative approaches to the role of speech and expression in the organization of societies.
Автор: S. Kenney; W. Reisinger; J. Reitz Название: Constitutional Dialogues in Comparative Perspective ISBN: 0333736907 ISBN-13(EAN): 9780333736906 Издательство: Springer Рейтинг: Цена: 20962.00 р. Наличие на складе: Есть у поставщика Поставка под заказ.
Описание: From Russia and Hungary to the United States and Canada, including Britain, France, and Germany, courts are increasingly recognised as political institutions that are important players in political systems.
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