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European integration, legal diversity and the conflict of laws

Abstract : How far does internal market integration require unification of the substantive laws of member states? If diversity can be maintained, how do traditional principles of the conflict of laws relate to mutual recognition? These issues are at the heart of two important contemporary debates within Europe, which are rarely connected with one another. This article aims to provide a link by suggesting that the conflict of laws could provide a more adequate tool of multi-level governance than substantive unification, preserving legal pluralism, if it is allowed to assume a regulatory function which it is has hitherto been denied in the European tradition (...).
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Horatia Muir Watt. European integration, legal diversity and the conflict of laws. Edinburgh Law Review, Edinburgh University Press, 2005, 9 (1), pp.6 - 31. ⟨hal-03603657⟩



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