This book provides a comparative assessment of the current state of private international law by exploring the fundamental philosophical, ideological, and methodological challenges encountered during the 20th century and the responses to those challenges in the western world.
Among the questions discussed are:
the dilemma between `conflicts justice' and `material justice';
the conflict between the goal of international uniformity and the need or desire to protect state or national interests;
the tension between the goals of certainty and flexibility;
the symbiosis of the multilateral, unilateral, and substantive methodologies; and
the antagonism or co-existence between choice-of-law rules and flexible `approaches', and between `jurisdiction-selecting' and `content-oriented' rules or approaches.
Written by some of the world's most distinguished scholars, this thought-provoking book provides insightful and diverse perspectives from nineteen countries. It is essential reading for any teacher or student of private international law or comparative law.
` Toutes les personnes intéressées par le droit comparé ... trouvent dans cet ouvrage un instrument de réflexion de grande qualité. '
Revue internationale de Droit comparé, 3 (2000)