Conflict of Laws Within the UK

This book examines both the theory and practice of the conflict of laws within the UK, focusing on the increasing significance of the impact of EU legislation, and the effect of the UK's changing constitutional arrangements.

This is the first major treatment of the conflict of laws within the UK, a subject often dealt with only incidentally in the main texts on private international law. In particular, the book examines the effect of the UK''s changing constitutional arrangements on questions of jurisdiction, choice of law and issues of recognition and enforcement which arise within the UK. The book offers practical guidance on the applicable rules in intra-UK conflicts situations with sections devoted to forum shopping within the UK, and other procedural matters. A chapter is also included on the impact of EU legislation on intra-UK conflicts, concluding with a discussion on how "Europeanization" might affect the conflict of laws in the UK. There is also coverage of how public policy functions in the conflict of laws. The book''s approach to the treatment of intra-UK conflicts is enhanced by a comparative analysis of the recent response of Canada and Australia to, respectively, interprovincial and interstate conflicts.