| Popis: |
The present dissertation deals with selected questions arising in the course of the application of choice of law rules and of the foreign law designated on the basis thereof. In this context, the dissertation analyzes general issues connected to the selected questions and then compares the possible solutions as implemented in Czech law, EU law and in selected foreign laws. As far as Czech law is concerned, attention is also paid to its historical development; the same is true about some of the foreign laws discussed in the dissertation. The dissertation focuses on selected wording and interpretation difficulties that used to arise and still arise in the context of particular legal instruments. First, two basic hypotheses are set out; their verification is one of the aims of the dissertation. The first is the question of whether the doctrine of choice of law rules represents a self- contained and self-sufficient system that - at least on a theoretical level - offers answers to all questions arising in the context of the application of choice of law rules. The second is the question of whether the concept of a bilateral choice of law rule, as commonly implemented today, facilitates international private law interaction and is - at least on a general level - a suitable way of governing international private... |
