| Abstract [eng] |
The thesis examines the legal problems arising in the context of international commercial litigation with the United Kingdom following Brexit. With the UK's withdrawal from the European Union, the direct legal framework previously governing cross-border civil and commercial disputes — the Brussels regime — ceased to apply between the two parties. The thesis analyses the consequential challenges in establishing jurisdiction, mutual recognition and enforcement of judgments, and the effective access to justice for parties engaged in UK–EU commercial disputes. The author concludes, among others, that 2019 Hague Convention is material to resolving the problems that have occurred and international commercial arbitration has emerged as the principal alternative dispute resolution mechanism for commercial relations between the United Kingdom and EU Member States in the post-Brexit era. |
