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Civil justice systems of the Member States of the European Union differ substantially. Despite recent trends towards convergence, each jurisdiction has its own way of defining how people can legitimately resolve disputes and enforce their rights and the obligations of others. The essays in this collection investigate the extent to which perceptions of differences between national civil justice systems affect businesses engaging in cross-border transactions when they choose the forum and the governing contract law, including the results of a major survey of European businesses on the impact that particular features of civil justice systems have on choices of forum and choices of law. This book constitutes a major assessment of the strengths and weaknesses of EU domestic civil justice systems, and the prospects for recent EU harmonisation measures.
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Civil justice systems of the Member States of the European Union differ substantially. Despite recent trends towards convergence, each jurisdiction has its own way of defining how people can legitimately resolve disputes and enforce their rights and the obligations of others. The essays in this collection investigate the extent to which perceptions of differences between national civil justice systems affect businesses engaging in cross-border transactions when they choose the forum and the governing contract law, including the results of a major survey of European businesses on the impact that particular features of civil justice systems have on choices of forum and choices of law. This book constitutes a major assessment of the strengths and weaknesses of EU domestic civil justice systems, and the prospects for recent EU harmonisation measures.