Private international law at the service of geopolitics.

Authors Publication date
2020
Publication type
Journal Article
Summary The geopolitical stakes of the apparently anodyne regime of the effects of foreign judgments at the international level are more complex and less rational than they may appear from a mere reading of the text of the new Hague instrument, which has come to fruition, against all odds, twenty years after the failure of the vast millennium project. These issues are to be sought in four directions: the new place of the European Union at the negotiating table, exclusive of that of the member states . the awakening of China to the soft power potential of private international law, in support of the economic empire embodied in the revival of the Silk Road . the change in the balance of power brought about by the Brexit and extending to the Commonwealth markets . the newly weakened position of the United States in the post-shame era. However, it cannot be ruled out that the uniform regime for the effects of foreign judgments will be caught up simultaneously in the new competition between the various dispute resolution models.
Publisher
Dalloz
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