Related Doctrines in Civil Law Systems 1
This chapter considers whether civil law jurisdictions of the world have doctrines that allow courts the discretion to decline to exercise jurisdiction when it otherwise exists. Particular attention is given to Germany, Japan, and the rules developed through the Brussels Regulation in the European Union. The development in Latin American nations of legislation designed to frustrate the application of the doctrine of forum non conveniens in the United States is also covered.
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