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Hi... just thought I should say that I'm kind of working round all sorts of international private law-related articles at the moment. My interest in it is that I've just sat my Honours exams in it. By contrast with other legal topics it doesn't seem to have had too much interest. I hope I'm not stepping on too many people's toes here. If someone could provide a North American input though, that might be helpful. Most of what I know concerns Scotland (my own lex domicilii and lex patriae!), England and the European dimension. -- Killiedaft 22:32, 24 April 2005 (UTC)
A good overview. I agree this is much undervalued area of the law, and poorly understood by many practitioners. I hope to contribute (carefully) to this page in due course. I am domiciled in Indonesia so I hope the perspective will help — Preceding unsigned comment added by Suastiastu ( talk • contribs) 23:43, 24 November 2005 (UTC)
We are always pleased to see new helpers — there is now a reasonable coverage of Conflict so your comments generally would be appreciated. David91 02:52, 25 November 2005 (UTC)
"=Non-geographical conflict of laws== Certain states apply multiple systems of law in one geographical area. For example, Sharia and national law (for ex-pats) co-exist in several Gulf states where common law has influenced the commercial code; also in several Indian states customary laws of certain castes and religions are enforceable on group members. Courts in such states apply principles of private international law (appropriately modified) to resolve the conflict."
I imgaine what is being referred to is the phenomenon of legal pluralism. I understand in some states the personal law applied (e.g. in matters of fmily law) can vary according to e.g. the religion of the person to whom it is applied. Like David91 I've not heard before of a direct comparison being made with private international law. In dualist states (i.e. states in whcih international law does not ipso facto form part of the muncipal law) those states may, to an extent, transform international law in to norms of domestic law (e.g. in the USA by allowing treaties to form part of US law but only so long as they do not conflict with the US Consititution) but I would not have described the rules that govern when this occured as a "conflict system". -- Lucifer(sc) 14:24, 2 April 2006 (UTC)
Hello guys,
I have noticed that we have:
Anyway, it is nice to meet collegues in Wikipedia. :-) Vlad fedorov 08:53, 18 March 2007 (UTC)
hey guys, i just have one question and i can't seem to find an answer to in anywhere on the net or wikipedia, do i'm using the talk page here. suppose that i live in country A and i commit internet fraud in country B through there servers whilst i still live in country A, now, country B finds out about my activities and tries to prosecute me but i live in country A could wither country A or B prosecute me for my fraud? —Preceding unsigned comment added by 124.190.161.81 ( talk) 10:20, 24 October 2007 (UTC)
The Choice of law article and this one should be merged. —Preceding unsigned comment added by 24.38.31.81 ( talk) 16:06, 24 May 2010 (UTC)
I propose a split, because "Private international law" is obviously altogether slightly different matters from the "Conflict of Laws" that were being talked about by Joseph Story, notwithstanding of the attempts by such authors as John Greenwood Collier of the Trinity Hall, Cambridge, et al., of deliberately confusing and inflating the two together for the purpose of selling his books, and being picked up by unsuspecting "lay readers" of less solid intellectual calibres and foundations, one of whom started this very article, amongst and along with a whole series of others. --- 212.50.182.151 ( talk) 14:59, 10 October 2013 (UTC)
Greetings, this is my first WIKI post. It's a topic I know a lot about -- I'm a professor of law and teach the subject. I'm common law trained but also expert in EU/Continental traditions, so have some opinions. The first is that it would be a MISTAKE to split PIL from conflict of laws. They are the same topic, essentially. Conflict of laws is the common law terminology, while private international law is the terminology used in the civil law world. WIKI should not perpetuate the misunderstandings between these 2 great legal traditions, but rather seek to bridge them so that communication and understanding are possible. I'm not sure how this works, but I'm a strong vote in favor of not splitting. I also agree with comment above under CHOICE OF LAW label that they should be combined. This is correct. Again, these are all different labels used to talk about the same basic sets of issues. What gets tricky is that there is so little agreement about how to bundle them. I've done a good deal of writing about it, trying to find ways to make sense of it, so am willing to help, though I have different writing priorities at the moment, but to some degree they overlap so I will try to add my perspective when time allows. For me, as a first time poster to WIKI, I still need to figure out how the process works. HelsBelles ( talk) 14:23, 15 October 2013 (UTC)
No to split. In continental Law, Private International Law is the same as "Conflict of Laws", though the latter term is never used and Private International Law is the only expression used. — Preceding unsigned comment added by 83.36.238.149 ( talk) 03:01, 14 January 2014 (UTC)
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Hi... just thought I should say that I'm kind of working round all sorts of international private law-related articles at the moment. My interest in it is that I've just sat my Honours exams in it. By contrast with other legal topics it doesn't seem to have had too much interest. I hope I'm not stepping on too many people's toes here. If someone could provide a North American input though, that might be helpful. Most of what I know concerns Scotland (my own lex domicilii and lex patriae!), England and the European dimension. -- Killiedaft 22:32, 24 April 2005 (UTC)
A good overview. I agree this is much undervalued area of the law, and poorly understood by many practitioners. I hope to contribute (carefully) to this page in due course. I am domiciled in Indonesia so I hope the perspective will help — Preceding unsigned comment added by Suastiastu ( talk • contribs) 23:43, 24 November 2005 (UTC)
We are always pleased to see new helpers — there is now a reasonable coverage of Conflict so your comments generally would be appreciated. David91 02:52, 25 November 2005 (UTC)
"=Non-geographical conflict of laws== Certain states apply multiple systems of law in one geographical area. For example, Sharia and national law (for ex-pats) co-exist in several Gulf states where common law has influenced the commercial code; also in several Indian states customary laws of certain castes and religions are enforceable on group members. Courts in such states apply principles of private international law (appropriately modified) to resolve the conflict."
I imgaine what is being referred to is the phenomenon of legal pluralism. I understand in some states the personal law applied (e.g. in matters of fmily law) can vary according to e.g. the religion of the person to whom it is applied. Like David91 I've not heard before of a direct comparison being made with private international law. In dualist states (i.e. states in whcih international law does not ipso facto form part of the muncipal law) those states may, to an extent, transform international law in to norms of domestic law (e.g. in the USA by allowing treaties to form part of US law but only so long as they do not conflict with the US Consititution) but I would not have described the rules that govern when this occured as a "conflict system". -- Lucifer(sc) 14:24, 2 April 2006 (UTC)
Hello guys,
I have noticed that we have:
Anyway, it is nice to meet collegues in Wikipedia. :-) Vlad fedorov 08:53, 18 March 2007 (UTC)
hey guys, i just have one question and i can't seem to find an answer to in anywhere on the net or wikipedia, do i'm using the talk page here. suppose that i live in country A and i commit internet fraud in country B through there servers whilst i still live in country A, now, country B finds out about my activities and tries to prosecute me but i live in country A could wither country A or B prosecute me for my fraud? —Preceding unsigned comment added by 124.190.161.81 ( talk) 10:20, 24 October 2007 (UTC)
The Choice of law article and this one should be merged. —Preceding unsigned comment added by 24.38.31.81 ( talk) 16:06, 24 May 2010 (UTC)
I propose a split, because "Private international law" is obviously altogether slightly different matters from the "Conflict of Laws" that were being talked about by Joseph Story, notwithstanding of the attempts by such authors as John Greenwood Collier of the Trinity Hall, Cambridge, et al., of deliberately confusing and inflating the two together for the purpose of selling his books, and being picked up by unsuspecting "lay readers" of less solid intellectual calibres and foundations, one of whom started this very article, amongst and along with a whole series of others. --- 212.50.182.151 ( talk) 14:59, 10 October 2013 (UTC)
Greetings, this is my first WIKI post. It's a topic I know a lot about -- I'm a professor of law and teach the subject. I'm common law trained but also expert in EU/Continental traditions, so have some opinions. The first is that it would be a MISTAKE to split PIL from conflict of laws. They are the same topic, essentially. Conflict of laws is the common law terminology, while private international law is the terminology used in the civil law world. WIKI should not perpetuate the misunderstandings between these 2 great legal traditions, but rather seek to bridge them so that communication and understanding are possible. I'm not sure how this works, but I'm a strong vote in favor of not splitting. I also agree with comment above under CHOICE OF LAW label that they should be combined. This is correct. Again, these are all different labels used to talk about the same basic sets of issues. What gets tricky is that there is so little agreement about how to bundle them. I've done a good deal of writing about it, trying to find ways to make sense of it, so am willing to help, though I have different writing priorities at the moment, but to some degree they overlap so I will try to add my perspective when time allows. For me, as a first time poster to WIKI, I still need to figure out how the process works. HelsBelles ( talk) 14:23, 15 October 2013 (UTC)
No to split. In continental Law, Private International Law is the same as "Conflict of Laws", though the latter term is never used and Private International Law is the only expression used. — Preceding unsigned comment added by 83.36.238.149 ( talk) 03:01, 14 January 2014 (UTC)
Hello fellow Wikipedians,
I have just modified 6 external links on Conflict of laws. Please take a moment to review my edit. If you have any questions, or need the bot to ignore the links, or the page altogether, please visit this simple FaQ for additional information. I made the following changes:
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This message was posted before February 2018.
After February 2018, "External links modified" talk page sections are no longer generated or monitored by InternetArchiveBot. No special action is required regarding these talk page notices, other than
regular verification using the archive tool instructions below. Editors
have permission to delete these "External links modified" talk page sections if they want to de-clutter talk pages, but see the
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source check}}
(last update: 18 January 2022).
Cheers.— InternetArchiveBot ( Report bug) 02:50, 12 August 2017 (UTC)