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Choice Of Law Clauses In Consumer Contracts: A Comparative Study Of American And E.E.C. Law, Jean-Marie Henckaerts
Choice Of Law Clauses In Consumer Contracts: A Comparative Study Of American And E.E.C. Law, Jean-Marie Henckaerts
LLM Theses and Essays
The selection of the law applicable to a certain relationship may seem to be the sole purpose of choice of law rules. However, it is questionable whether this choice should be made independent from the content of the various laws available. The selection of the most appropriate law cannot disregard the social, economic and political values that form the basis of substantive rules. In modern legal systems, social values such as consumer protection are recognized to a growing extent.
The present work explores the concept of choice of law – namely party autonomy with a focus on consumer contracts in …