نوع مقاله : علمی پژوهشی
نویسنده
استادیار دانشگاه گیلان
چکیده
کلیدواژهها
عنوان مقاله [English]
نویسنده [English]
There is no international judicial tribunal to deal with disputes derived from international private relationships. These claims are subject to the jurisdiction of domestic courts or agreed parties’ arbitrator. Forum conflict rules, similar to other rules of private international law, are considered as within countries’ domestic law and are mostly derived from the customary civil procedures in domestic law. Therefore, there is over-diversity for litigation of certain cases in civil procedural rules of several countries. Despite wide differences about grounds and barriers of jurisdiction, competence based on defendant domicile and consensual submission have been recognized in most legal systems.
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