The European Private International Law of Employment
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| Anteprima |
The
European Private International Law of Employment provides a descriptive
and normative account of the European rules of jurisdiction and choice
of law which frame international employment litigation in the courts of
EU Member States. The author outlines the relevant rules of the Brussels
I Regulation Recast, the Rome Regulations, the Posted Workers Directive
and the draft of the Posting of Workers Enforcement Directive, and
assesses those rules in light of the objective of protection of
employees. By using the UK as a case study, he also highlights the
impact of the 'Europeanisation' of private international law on
traditional perceptions and rules in this field of law in individual
Member States. For example, the author demonstrates that the private
international law of the EU is fundamentally reshaping English conflict
of laws by almost completely merging the traditionally perceived
contractual, statutory and tortious claims into one claim for
choice-of-law purposes.
