Awarded with the Prize of the Swiss Institute of Comparative Law 2008
Since 1989, Europe has witnessed an exponential increase in the number of so-called “registered partnership” schemes introduced alongside marriage. The diversity of registration schemes has created numerous problems in cases involving an international or cross-border element. This book focuses on these new registration schemes and is divided into two main parts. The first part is dedicated to the analysis and comparison of the substantive law rules of Belgium, France, The Netherlands, Switzerland and the United Kingdom (England & Wales, Scotland and Northern Ireland). On the basis of this comparison, it is concluded that although these registration schemes appear to be dissimilar, they all fulfil a common function. This conclusion serves as the starting point for the second part, which examines the private international law rules applicable to such relationships. Unification of these rules is deemed to be not only desirable, but also feasible.
This book serves as a reference tool for all those who require information regarding the substantive law rules in the countries researched, as well as for those interested in the private international law aspects of these new forms of non-marital registered relationships.
De individuele hoofdstukken zijn (nog) niet beschikbaar.
‘... the European Family Law Series [plays] an important role in informing lawyers across Europe and beyond about developments in other jurisdictions, and in continually assessing the potential for hamonisation in the field.’
Brian Sloan in Rabels Zeitschrift 74 (2010)
The European Family Law series is dedicated to the harmonisation and unification of family and succession law in Europe. The series includes comparative legal studies and materials as well as studies on the effects of international and European law making within the national legal systems in Europe.
The series is published under the auspices of the Organising Committee of the Commission on European Family Law:
- Professor Katharina Boele-Woelki (The Netherlands),
- Professor Frédérique Ferrand (France),
- Professor Cristina González Beilfuss (Spain),
- Professor Maarit Jänterä-Jareborg (Sweden),
- Professor Nigel Lowe (United Kingdom),
- Professor Dieter Martiny (Germany) and
- Professor Velina Todorova (Bulgaria).
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