private international law
Let an agent explain private international law, relay jurisdiction, choice of law and recognition of judgments, regional systems and Hague conventions from legal sources in general terms, describe the named systems, point people to specialist lawyers and central authorities, and distinguish private international law from public international law, comparative law, international commercial arbitration and immigration law.
Research draft, second pass
A second pass drafted this model: the structure a model of this thing needs, and what is known about it in the world. The line under this one says how the second half was obtained - researched against sources, or recalled without web access, in which case nothing here was read anywhere and every claim is a lead to verify. Unreviewed either way.
written by Claude from model knowledge without web access - no source was read, every claim is a lead to verify
Researched by: Claude
Purpose and description
Let an agent explain private international law, relay jurisdiction, choice of law and recognition of judgments, regional systems and Hague conventions from legal sources in general terms, describe the named systems, point people to specialist lawyers and central authorities, and distinguish private international law from public international law, comparative law, international commercial arbitration and immigration law.
The body of law that determines which country s courts have jurisdiction over cases with foreign elements, which country s law applies, and whether foreign judgments are recognised and enforced, also called conflict of laws, as in conflict of divorce laws and conflict of laws in the United States; national and regional systems the registry aliases name include private international law in the European Union, harmonised through regulations such as Brussels I bis and Rome I and II, and in Switzerland and Tunisia, codified in national statutes, while the Hague Conference on Private International Law develops conventions on child abduction, service of documents and choice of court. People with cross-border family or commercial disputes should seek specialist legal advice.
What it is for: Resolving cross-border private legal disputes.
It can be explain core questions; relay regional systems and conventions; describe named systems; point to legal help.
Distinguishing features
Cross-border private matters
Three core questions
National and regional rules
Hague conventions
What it looks like
Not a physical object; seen in statutes, regulations, treaties and court decisions.
Physical character
Hague Conference founded: 1893 year - permanent from 1955
Swiss PIL Act: 1987 year
Hague Child Abduction Convention: 1980 year
How it is recognised
Law on jurisdiction, applicable law and recognition
Private international law in Tunisia, private international law in Switzerland, conflict of divorce laws, conflict of laws in the United States, private international law in the European Union
Public international law governs states; comparative law compares systems; arbitration is private dispute resolution; immigration law covers entry and residence
Related models
is a kind of - in registry terms
is developed by -
includes - EU instrument
is contrasted with -
In practice
Families and kinds
jurisdiction rules
choice of law rules
recognition and enforcement of judgments
family and succession conflicts
commercial conflicts
Standards and regulation
EU Brussels I bis, Rome I, Rome II and Brussels II ter regulations
Hague conventions
National PIL codes
Failure modes and hazards
Giving legal advice
Stale rules after reforms
Missing child abduction urgency
Also called
Where this came from
wikidata · CC0 1.0
Drafted structure
Bundle to layer to finding to question, as the second pass will find it: 4 bundles · 8 layers · 8 findings · 16 questions.
Understand What private international law is.
Definition.
Definition
Definition.
Definition
Definition.
- Has a child been taken abroad without consent, in which case contact police and the national central authority for the Hague Convention urgently, and seek a specialist lawyer? boundary
- What is private international law, and how does it differ from public international law, comparative law, arbitration and immigration law? definition
Systems
Named systems.
Systems
Systems.
- How do the EU, Switzerland, Tunisia and the US handle conflicts, and what are conflicts of divorce laws? definition
- Which entry fits the specific system? action
Core questions Core questions.
Regulation.
Jurisdiction
Jurisdiction.
Jurisdiction
Jurisdiction.
- How do courts decide jurisdiction in cross-border cases, in general terms? provenance
- Which references are standard? provenance
Choice of law
Applicable law.
Choice of law
Choice of law.
- How do connecting factors such as habitual residence determine applicable law? provenance
- Which sources are cited? provenance
Instruments Instruments.
Regulation.
EU
EU regulations.
EU
EU.
- What do Brussels I bis and Rome I and II cover? provenance
- Which entry fits Rome I Regulation? action
Hague
Hague conventions.
Hague
Hague.
- Which Hague conventions address child abduction, choice of court and judgments? provenance
- Which entry fits Hague Convention on the Civil Aspects of International Child Abduction? action
Context Debates.
Attribution.
Public policy
Public policy exception.
Public policy
Public policy.
- How does the public policy exception limit foreign law, with debates attributed? provenance
- Is the presentation neutral and attributed? boundary
Current rules
Reforms.
Current rules
Current rules.
- What recent reforms apply, checked against current sources? provenance
- Is the information current? boundary
What the second pass must settle
- Should national PIL systems be separate entries?
- How should Hague conventions be linked and kept current?
- Should conflict of divorce laws be moved to family law entries?