THE CONTRACTUAL FORUM A COMPARATIVE STUDY
AbstractThis article provides a discussion of the law relating to forum selection agreements as it stands in both America and the British Commonwealth. Citing the draft Convention on the General Jurisdiction of Contractual Forums prepared by the governing board of the Hague Conference, the article offers a comparison of the two legal systems with each other and with the provisions of the draft Convention. The author first outlines the circumstances under which such agreements arise and proceeds with an analysis of the operation of forum selection agreements and how that operation might be affected by the draft Convention.
Keywords:Comparative Law, Conflict of Laws
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