In this chapter the book focuses on public policy as the third limit of the international choice of forum, relevant for asymmetric clauses. The chapter addresses the question to what extent public policy test can be applied in respect of asymmetric choice of forum agreements under the Brussels-Lugano regime and the New York Convention.

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Public Policy

  • Richard Schmidt

摘要

In this chapter the book focuses on public policy as the third limit of the international choice of forum, relevant for asymmetric clauses. The chapter addresses the question to what extent public policy test can be applied in respect of asymmetric choice of forum agreements under the Brussels-Lugano regime and the New York Convention.