ZVglRWiss – Zeitschrift für Vergleichende Rechtswissenschaft 3/2025
A brand new situation of ZVglRWiss – Zeitschrift für Vergleichende Rechtswissenschaft is now obtainable and contains contributions on EU personal regulation, comparative regulation, personal worldwide regulation, and particular person European personal regulation regimes.
The total desk of content material will be accessed right here.
The brand new situation 3/2025 contains:
Jürgen Basedow’s Contribution to Comparative Regulation Methodology and Its Future Position
Katharina Boele-Woelki displays Basedow’s contributions to comparative regulation and its future function, with a concentrate on his views on the methodological ideas of comparative authorized analysis. Within the wider ongoing debate on methodology in comparative regulation, Basedow supplies sensible, concrete arguments. Key discussions embrace practical versus cultural approaches, and micro- versus macro-comparative analysis.
Der kollektive Prozessvergleich aus rechtsvergleichender Perspektive
Karl Wörle discusses the relevance of elaborate procedural mechanisms to guard the pursuits of represented customers. The US class motion with its sturdy custom of personal dispute decision would supply helpful impulses, which have been strongly adopted within the Netherlands. The prolific worldwide expertise needs to be capitalized on for Germany and Austria – contemplating the peculiarities of collective redress procedures and nationwide authorized cultures – to derive impulses for future legislative coverage.
Lawsuits as Weapons? The EU’s Anti-Slapp Directive Strikes Again
Madeleine Petersen Weiner investigates and discusses the EU’s Anti-Slapp provisions and compares the European Directive with the U.S. Anti-Slapp Laws. Having originated within the U.S., SLAPPs (Strategic Lawsuits Towards Public Participation) now more and more additionally happen within the EU. SLAPPs are thought of abusive lawsuits as plaintiffs use the civil court docket system to silence opponents. On account of their risk to public participation – and in the end to guard and foster democratic debate – the EU has enacted the so-called Anti-SLAPP Directive.
Unechte Inlandsfälle unter der Brüssel Ia-VO
Salih Okur investigates the CJEU’s resolution in Inkreal and in FTI. In Inkreal, the CJEU lately held that a world factor within the sense of the Brussels Ia Regulation will be established by a jurisdiction settlement between events domiciled in the identical Member State in favour of one other Member State. Not a 12 months later, in FTI, the CJEU held that the worldwide factor is also established by the overseas vacation spot of a package deal journey association between events domiciled in the identical Member State. This paper proposes to know the “worldwide factor” as an “worldwide battle of jurisdiction”. Towards this commonplace, the CJEU’s resolution in Inkreal is convincing whereas the opinion on FTI just isn’t.
