Showing papers in "International Comparative Jurisprudence in 2018"

TL;DR: In this paper, the conditions for the recognition and enforcement of foreign judgments in Turkey under Turkish law, with an emphasis on judicial decisions and a more follows reference to arbitration decisions, are presented.

TL;DR: In this article, a comparative analysis on the tenant's right to terminate is presented, and the authors argue that tenants in Estonia have no real choice to opt for the flexibility needed without a trade-off in terms of stability.

TL;DR: In this paper, the authors discuss the role of specific fiduciary duties, as well as the various potential problems arising from a lack of such duties in PE/VC fund managers.

TL;DR: In this article, the authors present the Directive's prerequisites for manufacturer liability and examine legal gaps arising from the definition of "product" in the light of the characteristics of fully autonomous and connected vehicles.

TL;DR: In this paper, the compatibility of maternity leave with the principle of equal treatment between the delivering mother and the father is investigated, and a way forward to find a better balance between the recognition of women's biological specificities and the rights of all parents to spend time with their children is discussed.

TL;DR: In this paper, the consequences of fraud according to the Turkish Code of Obligations (TCO) and Law on Obligational Relationships of Kosovo (LORK) are discussed.

TL;DR: In this paper, the authors provide an overview of the essential features of the Energy Charter Treaty (ECT), keeping in mind that the European Union needs an efficient and integrated internal energy market, they analyze the ECT provisions related to both investment protection and problems of arbitration arising from these provisions.

TL;DR: In this article, the authors compared Estonian, German, Latvian and Lithuanian law by comparing the three main active procedural rights of creditors: submitting a proof of claim, voting at a general meeting of creditors, and satisfying the claim.

TL;DR: In this paper, the authors assess the impact of the Third Energy Package (Third Energy Package) on Czech law and the role of the Czech Republic in the formation of a competitive gas market following the application of legislative measures in the sector.

TL;DR: In this paper, the authors argue that the margin of appreciation is wider for the more influential and politically powerful jurisdictions than for newer states before the court, those more susceptible and amenable to policy dictation, who are subject to a differential measure of state discretion.

TL;DR: The post-mortem privacy regulation by the legal framework and by contracts is analyzed, information about existing measures to protect Internet user’s data post- autopsy is provided and the possibilities to improve them are discussed.

TL;DR: In this article, the authors analyse the distinctive and connecting aspects of organized crime and terrorism, presenting the criminological elements of these two phenomena and legal aspects involved in fighting them.