Private International Law at the End of the 20th Century: Progress or Regress?

This study provides a comparative assessment of the current state of Private International Law by exploring the fundamental philosophical, ideological, and methodological challenges encountered during the 20th century and the responses to those challenges in the western world. Among the questions discussed are: the dilemma between "conflicts justice" and "material justice"; the conflict between the goal of international uniformity and the need or desire to protect state or national interests; the tension between the goals of certainty and flexibility; the symbiosis of the multilateral, unilateral, and substantive methodologies; and the antagonism or co-existence between choice-of-law rules and flexible "approaches", and between "jurisdiction-selecting" and "content-oriented" rules or approaches. Providing insight and diverse perspectives from 19 countries, this book should be useful to teachers or students of private international law or comparative law.