Article: Comparative forum non conveniens and the Hague convention on jurisdiction and judgements

I. INTRODUCTION

The doctrine of forum non conveniens is one part of a complex web of issues relating to the ability of courts to decline jurisdiction in cases connected to more than one legal system.1 While the Latin term was first used in Scotland in the late nineteenth century, the doct rine is generally agreed to have its genesis in earlier Scottish cases of the seventeenth century. Both the doctrine and the term appear in most common law systems following the British model, but there often are important differences in the focus and effect of the doctrine from country to country. At base, the doctrine allows a court that has jurisdiction to stay or dismiss proceedings where there is a ...

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