No description available.

Both the civil and the common law legal systems have, as a result of their historical development, elaborated different conceptions of the law of agency. Given the existing divergence in approaches and rules relating to agency, the international unification of law in this field, although highly demanded by commercial practice, seems a problematic, but not impossible, task. The decades long efforts of a large number of states, international organisations and individuals to provide uniform rules of international agency law have resulted in the adoption of two conventions, namely, the Hague Convention on the Law Applicable to Agency (1978) aimed at the unification of the conflict rules of agency, and the UNIDROIT Convention on Agency in the International Sale of Goods (1983) which attempts to provide uniform material rules. / This thesis provides a detailed analysis of the uniform rules set out in both agency Conventions. The main purpose of this analysis is to assess the extent to which uniformity is achieved by these Conventions. However, in order to reveal the divergence of approaches between the civil and common law legal systems and define the "conflict areas" of international agency, the present study also contains a comparative survey of material and conflict rules of agency existing in the two systems.

In a three point argument, it is asserted that general principles of law can be used to establish liability of corporations for massive violations of human rights. First, there is a lacuna in the law in this subject. Second, the constructivist approach to international relations contends that international norms are obeyed when they are internalized, so, conversely, the assertion is made that domestic law could be used to identify international norms, expanding the usefulness of general principles of law. Thirdly, general principles of law can be identified by comparative law methodology, so using one comparative method, The Common Core of European Private Law, should uncover principles of corporate liability. Lastly, an adaptation of this methodology is then applied to four countries.

Includes abstract / Includes bibliography / xviii, 655 leaves ; 30 cm. / Title page, contents and abstract only. The complete thesis in print form is available from the University Library. / Thesis (Ph.D.)--University of Adelaide, 1987

Univ., Diss.--Saarbrücken, 2004.

Thesis (doctoral)--Universität Potsdam, 2006. / Includes bibliographical references (p. [644]-672) and index.

Univ., Diss.--Mainz, 2003. / Literaturverz. S. XV - XXXV.

Thesis (J.C.L.)--Catholic University of America, 2003. / Includes bibliographical references (leaves 44-51).

Thesis (J.C.L.)--Catholic University of America, 2003. / Includes bibliographical references (leaves 44-51).

Thesis (J.C.L.)--Catholic University of America, 2003. / Includes bibliographical references (leaves 44-51).