Journal

Volume 42 | Number 3 Summer 2007

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Developing Global Transnational Harmonization Procedures for the Twenty-First Century: The Accelerating Pace of Common and Civil Law Convergence

by Louis F. Del Duca

Summary

  1. Procedural Options – The New Challenge
    1. General Considerations – Key Actors – Selecting Harmonization Areas and Procedures
    2. Conventions: CISG and European Convention on Human Rights
    3. Model Laws
    4. Guidelines
    5. Voluntary Contractual Applicability Texts: Incoterms, Uniform Customs and Practices, Arbitration Rules
    6. Use of Regulations, Directives, and ‘Mutual Recognition’ Procedures in the European Union
    7. Use of Conventions, Recommendations, and Exchange of Views in the Council of Europe
    8. Achieving Uniformity in Practice
  2. Specific Harmonization Areas
    1. Case Law as a Source of Law
      1. The “Goodhart” and “Zweigert-Kötz-Cappelletti” Eras and Entry into the Third Millennium
      2. Goodhart Era
      3. Zweigert-Kötz-Cappelletti Era
      4. Entry into the Third Millennium
      5. Experience of Constitutional Courts in Europe and Case Law in Civil Law Systems
      6. Case Law Experience of the European Union: An Example of Civil and Common Law Convergence in Practice
      7. Other Perspectives: The Role of Precedent in Mexico
    2. Status of Selected Current Substantive Harmonization Projects
      1. Principles of European Contract Law
      2. European Civil Code
      3. UNIDROIT Principles 2004: A Further Step Toward a Global Contract Law
      4. Global Commercial Code
      5. Other International Regimes’ Impact on Convergence: UNCITRAL and the World Trade Organization
    3. Principles and Rules of Transnational Civil Procedure – An ALI and UNIDROIT Cooperative Harmonization Project
    4. Impact of Electronic International Reporting Systems on Convergence

Footnotes

For complete footnote citations, download the PDF.

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