Transnational Protection against Discrimination - The International Private Law of Anti-Discrimination
01.02.2010
How is the applicable anti-discrimination law to be determined in individual cross-border cases? Jan D. Lüttringhaus answers this question on the basis of an increasingly Europeanised body of private international law (PIL).
Discrimination often occurs in cross-border contracts. It is in this setting that different cultures and concepts as to (e.g. gender and racial) equality collide. Thus, transnational protection against discrimination raises numerous questions - in particular with regard to international labor and insurance contracts. Jan D. Lüttringhaus endeavors to provide answers on the basis of European private international law. He examines the area of international contract law as well as transnational protection against discrimination in corporate bodies. Given that some EU Member States impose further sanctions under criminal and administrative law, the author outlines the conflicts between public and private cross-border enforcement of non-discrimination laws.
Jan D. Lüttringhaus, Grenzüberschreitender Diskriminierungsschutz – Das internationale Privatrecht der Antidiskriminierung, Studien zum ausländischen und internationalen Privatrecht 234,
Mohr Siebeck, Tübingen 2010, XXV+449 pages.