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Introduction | |
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Roots and context of the conflict of laws within the UK | |
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Introduction | |
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Necessary conditions for the development of the conflict of laws | |
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Barriers to the development of conflict of laws rules | |
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Failure of seventeenth century political changes to remove the underlying need for conflict rules | |
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Early development of conflict rules within the British Isles | |
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Conclusion | |
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The constitutionalization of conflicts within the UK | |
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The constitutionalization of conflicts | |
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The constitutionalization of conflicts prior to the devolution settlements | |
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The constitutionalization of conflicts and the devolution settlements | |
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Undesirability of further constitutionalization of conflicts | |
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Conclusion | |
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The internalization of conflicts within the UK | |
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The internalization of conflicts | |
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UK common market law | |
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Recognition and enforcement | |
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Internalization of conflicts and judge-made law | |
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Conclusion | |
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The application of conflict rules within the UK | |
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Introduction | |
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Similarity of conflict rules within the UK | |
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Procedural matters | |
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Status | |
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The laws of property and succession | |
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Tort and delict | |
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Intra-national forum shopping in the UK | |
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The effect of the new constitutional arrangements on intra-national conflicts in the UK | |
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Conclusion | |
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The impact of European Union legislation on intra-UK conflict rules | |
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Introduction | |
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Jurisdiction | |
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Choice of law | |
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Recognition and enforcement | |
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Europeanization: the beginning of the end for conflict of laws? | |
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Public policy in intra-UK conflict of laws | |
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The different facets of public policy | |
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Underlying public policy and internal public policy in the UK | |
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The application of external public policy within the UK at common law | |
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The availability of external public policy objections under statute within the UK | |
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Constitutionalization and external public policy | |
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Community public policy | |
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Human rights | |
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Conclusion | |
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Conclusion | |
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Development of conflict rules in the UK | |
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Dealing with intra-national conflicts | |
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Scope of traditional conflict rules in intra-national disputes in the UK | |
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Public policy | |
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The impact of European Union membership | |