LL.M. (International Commercial Law) / This dissertation concerns a comparative analysis of Brazilian, Indian and South African private international law principles on the exercise of jurisdiction in international civil and commercial cases. The intention is to uncover the fundamental grounds of jurisdiction in these legal systems and in doing so draw attention to their comparable characteristics. Emphasis is placed on matters of a commercial nature. Furthermore, a discussion of the Hague Convention on Choice of Court Agreements provides insight on the Convention’s purpose and its possible influence on and implications for jurisdictional rules found in the private international law of the IBSA countries should they become members to the Convention.
Identifer | oai:union.ndltd.org:netd.ac.za/oai:union.ndltd.org:uj/uj:13769 |
Date | 15 July 2015 |
Creators | Barnard, Alicia Priscilla |
Source Sets | South African National ETD Portal |
Detected Language | English |
Type | Thesis |
Rights | University of Johannesburg |
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