LA CONFLUENȚA DINTRE DREPTUL INTERNAȚIONAL PRIVAT ȘI DREPTUL UNIUNII EUROPENE
THE CONFLUENCE OF PRIVATE INTERNATIONAL LAW AND EU LAW

Summary/Abstract: Adopting an international systemic perspective, the division of private international law into three components of jurisdiction, applicable law and the recognition and enforcement of foreign judgments may be seen in the fresh light. The existence of different national legal systems creates the potential for inconsistent legal treatment of disputes. The three components of private international law are usually distinguished and examined separately. While this separation is understandable, it risks missing the interaction and intersection between EU law and Private law. Choice of law rules try to find a single most closely connected law to a dispute, although there can be disagreement on how such a connection should be measured.

• Details
• Contents