Interconnection of the EU Regulations Brussels I Recast and Rome I

This book deals with the interconnection between the Brussels I Recast and Rome I Regulations and addresses the question of uniform interpretation. A consistent understanding of scope and common terms is suggested by Recital 7 of the Rome I Regulation. Indeed, what would be more reassuring than to always call a contract a contract? The author takes a closer look at the Regulations' systems, their individual justice models, guiding principles, and their balance of flexibility and legal certainty. It starts from the premise that such analysis should prove particularly rewarding as both legal acts have their specific DNA: The Brussels I Recast Regulation has a procedural focus when it governs the allocation of jurisdiction and the free circulation of judgments. The multilateral rules under the Rome I Regulation, by contrast, are animated by conflict of laws methods and focus on the delimitation of legal systems. 0This fourth volume in the 'Short Studies in Private International Law' Series is primarily aimed at legal academics in private international law and advanced students. But it should also prove an intriguing read for legal practitioners in international litigation.