| 单词 | Total renvoi |
| 释义 | 完全反致 The doctrine that a court may attempt to approximate the result that would have been reached by a foreign court as referred to in the choice of law rules of that court, as if the judge were sitting as the foreign court hearing the case. This would include that court’s answer to the problem of renvoi. This approach has received recognition in the United Kingdom: In re Annesley [1926] 1 Ch 692. Also known as ‘foreign court theory’ or ‘English theory’. See also Conflict of laws; Renvoi; Single renvoi. 按此原則，法院在作出決定時，可嘗試與就該等法院的法律規則選擇問題而轉介的外國法院會已經達致的結果接近，猶如有關的法官在外國法院開庭聆訊有關的案件一樣。這包括該等法院對反致問題的回答。此等方法在英國獲認可： Re Annesely [1926] 1 Ch 692。另稱「外國法院理論」或「英國理論」。另見 Conflict of laws; Renvoi; Single renvoi。 |
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