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Nationality, Domicile And Habitual Residence - Does The New German Citizenship Law Call For A Change Of A Principal Connecting Factor In Private International Law ?, Marc Cziesielsky

LLM Theses and Essays

The purpose of the new citizenship law which was proposed by the new German federal government was to give legal aliens living in Germany a choice to become German citizens without having to give up the nationality which was conferred on them by their parentage or descent. This thesis will question whether this rigid concept should be completely abolished after an assessment of both the constitutionality and the exact implications of the new citizenship law. In the light of the conclusions, the comparative part of this thesis will then focus on a more general approach and will compare the concepts …

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 …