This chapter provides a detailed comparison of the doctrines of forum non conveniens as applied in the four common law jurisdictions considered in Chapters 2-5. It reviews the basic requirements of the doctrine in each country and catalogues similarities and differences dealing with the requirement of an available alternative forum, allocation of the burden of proof, consideration of private interest factors, levels of trail court discretion, the ability to impose conditions on a stay or dismissal, and the treatment of foreign plaintiffs.
Keywords: forum non conveniens, declining jurisdiction, discretion, burden of proof, private interest factors,