EAN: 9783319943480

SPRINGERBRIEFS IN LAW A CROSS BORDER STUDY OF...

This book compares the law on provisional measures of common law and civil law countries  the
goal being to identify and compare their main advantages and disadvantages. The guiding concept
is a well-known statement by the Justices of the US Supreme Court expressed in the famous Grupo
Mexicano case  according to which the age of slow-moving capital and comparatively immobile
wealth has now passed  and the 21st century requires a fresh look at the law of provisional
measures. In the quest to find a model for interim relief  the Mareva Injunction  subsequently
renamed the 'Freezing Order' in the English Civil Procedural Rules  is used as the benchmark to
which each of the targeted systems discussed here is compared. This is because international
scholarship  as well as e.g. the US Supreme Court  generally consider the Mareva Injunction to
be the most effective and farthest-reaching provisional remedy. The analysis suggests that the
Mareva Injunction   Freezing Order represents the type of relief that will most likely continue
to dominate as the most efficient and farthest-reaching interim measure in the years to come.

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