The paper follows up on the arguments introduced in the author’s article Mutual Trust as a Way to an Unconditional Automatic Recognition of Foreign Judgments. This paper, titled Mutual Trust between the Member States of the European Union and the United Kingdom after Brexit: Overview discusses, whether there has been a loss of mutual trust between the European Union and the United Kingdom after Brexit. The UK, similarly to EU Member States, has been entrusted with the area of recognition and enforcement of judgements thus far. Should the Member States decrease the level of mutual trust in relation to the UK only because the UK ceased to be part of the EU after 47 years? Practically overnight, more precisely, the day after the transitional period, should the Member States trust the UK less in the light of legislative changes? The article also outlines general possibilities that the UK has regarding which international convention it may accede to. Instead of going into depth, the article presents a basic overview. However, this does not prevent the article to answer, in addition to the questions asked above, how a choice of access to an international convention could affect the level of mutual trust between the UK and EU Member States.
Need of private international law arises because the internal laws of different countries differ from each other. If the internal laws of the countries of the world lay down uniform rules, then probably there will not be any need for private international law. But then, difference is not only in the internal laws of the different countries, but also in the private international laws of different countries, on account of which sometimes conflicting decisions are pronounced by the courts of different countries on the same matter. Thus, need for Unification of Private International law Rules arise.
The paper deals with the principle of reciprocity in the field of recognition and enforcement of foreign decisions. The aim is to ascertain the approach of the Czech legal doctrine and the rules of international procedural law in relation to this institute. The issue of reciprocity outside the European judicial area is addressed, as well as the question of whether reciprocity is a non-essential condition in the area of recognition and is interchangeable with other mechanisms affecting this issue.
Apart from international arbitration, where common state approaches may be seen, e.g. in the field of recognition and enforcement of arbitral awards, some contributions focus on national arbitration, which can bring a comparative point of view of arbitration in different states. Several contributions relate to investment arbitration, in particular, following the Achmea decision. From the most up-to-date topics, some papers are devoted to the COVID-19 pandemic or blockchain technology and their impact on arbitration. Also, the so-called Macao arbitration framework statutory established in 2020 by China will be presented. Traditional topics such as determining the applicability of non-state body of law or rules of law in arbitration or the institute of public policy exception are also included. Arbitration and the issue of double taxation may also bring attention and be beneficial to conference diversity.respective obligations are discussed.
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