Abstract
Compares the judgments issued by courts in the UK, US, Canada and Singapore in claims invoking maritime law by creditors of the insolvent O.W. Bunker Group, and assesses their implications for the related cross-border insolvency proceedings and the use of cross-border insolvency agreements. Argues that the courts' concern was for uniformity of outcomes, achieved with a minimum co-ordination approach, instead of developing common legal principles.
Original language | English |
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Pages (from-to) | 245-252 |
Number of pages | 8 |
Journal | International Company and Commercial Law Review |
Volume | 28 |
Issue number | 7 |
Publication status | Published - 2017 |
Keywords
- insolvency
- comity
- comparative law
- cross-border insolvency
- co-operation insolvency
- maritime liens
- shipping law