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LL.M. / The objective of this study is to identify the legal systems that should be applied in terms of South African private international law to the different contractual relationships in respect of a documentary letter of credit. In South Africa no legislation or (binding) case law in point exists. A comparative study is therefore made of the relevant legal rules and principles in the following countries: the United Kingdom; Germany; the Netherlands; Canada; Australia; and the United States of America. It is submitted that, in the absence of either an express or a tacit choice of a legal system by the parties, the proper law of a documentary letter of credit transaction in South African private international law should be – 1) in respect of the contractual relationship between the applicant and the issuing bank: the law of the country where the issuing bank is situated; 2) in respect of the contractual relationship between the issuing bank and the correspondent bank (whether confirming or merely advising): the law of the country where the correspondent bank is situated; 3) in respect of the contractual relationship between the confirming bank and the beneficiary: the law of the country where the confirming bank is situated; 4) in respect of the contractual relationship between the issuing bank and the beneficiary – a) where a correspondent bank (whether confirming or merely advising) is involved: the law of the country where the correspondent bank is situated; b) where no correspondent bank is involved: the law of the country where the issuing bank is situated.

Univ., Diss.--Paris, 2004.

Thèse--Université de Nancy. / "Bibliographie": p. [127]-128.

Thesis (doctoral)--Universität, Wien, 2009. / Includes bibliographical references and register.

Traditionally, public international law and private international law were perceived as two different categories of law; the former governing the international relations between states and the latter those between private individuals. Their relation is based upon an evolutionary development from private to public, and from municipal to international, law. In the modern world, this evolution has culminated in a dynamism reflected in numerous interactions between a wide range of different actors. As a result, the former boundaries between the public and private law, as well as the international and municipal law dichotomy, have become blurred. In an emerging global society, these four major categories have entered a dynamic dialogue that equally challenges both legal theory and practice. This dialogue is centred around a functioning global legal framework, in which public international law and private international law can---due to their distinct scopes of application---answer many unanswered questions, providing that they speak with one voice.

Thesis (M.A.)--Naval Postgraduate School, 2004. / "Report date September 2000." Includes bibliographic references.

Univ., Diss.--Osnabrück, 2005. / Literaturverz. S. 311 - 328.

Thesis (LL.M.). / Written for the Faculty of Law. Title from title page of PDF (viewed 2008/05/13). Includes bibliographical references.

Thesis (doctoral)--Universität München, 1976. / Includes bibliographical references (p. viii-lviii).