Comparative law Books

Book SynopsisCooperation and Engagement in the Asia-Pacific Region brings together contributions from leading experts around the world in the law of the sea. The volume addresses topics such as regional cooperation, protection and preservation of the marine environment, freedom of navigation, sustainable fisheries, and future cooperation within the important Asia-Pacific region. This book provides valuable insight into a region that encompasses many important maritime regions, and harbors promising opportunities for maritime cooperation and engagement.Table of ContentsPreface Acknowledgments List of Illustrations Featured Remarks Reflections on the Status and Prospects for Deep Seabed Mining in 201  Michael Lodge Reflections on the Past 25 Years of Ocean Law and Policy  David A. Balton Maritime Autonomous Surface Ships in International Law: New Challenges for the Regulation of International Navigation and Shipping  Aldo Chircop Part 1 Spotlight on Regional Cooperation 1 Military Cooperation and International Custom in the Asia-Pacific Region  John G. Hannink 2 Peace through Joint Marine and Cruise Tourism in the Disputed South China Sea Islands: Opportunities and Challenges  Yann-huei Song 3 Multilateral Cooperation in Resolving or Managing International Issues  Helmut Tuerk 4 Jurisdictional and Substantive Aspects in the Application of unclos<\sc> Article 83(3) in Recent International Decisions  Xinjun Zhang Part 2 Protection and Preservation of the Marine Environment 5 Candy and Poisons: Protecting Marine Environments While Meeting Societal Needs  Daniel Rittschof 6 The Duty to Cooperate in the Protection and Preservation of the Marine Environment  Chie Kojima 7 Environmental Impact Assessments in Protection and Preservation of the Marine Environment  Tianbao Qin and Fang Hou 8 Increasing Challenges to the Future Marine Environment  Stephen A. Macko Part 3 Freedom of Navigation 9 Freedom of Navigation: Where to Go When Political Agenda Overshadows Legal Substance  Nong Hong 10 An Archival History of the Creation and Early Implementation of the Freedom of Navigation Program  James Kraska 11 Military Activities in Foreign Exclusive Economic Zones: Identification and the Application of Law  Xinmin Ma 12 Freedom of Navigation: Practices of Vietnam  Lan-Anh T. Nguyen Part 4 Straits Governance, including Malacca/Singapore 13 The International Straits Regime: Notes on Uncertainties and “Other” Straits in the Northeast Asia-Pacific Region  Ted L. McDorman 14 Passage through Indonesian Waters on Routes Used for International Navigation  Robert Beckman and Dita Liliansa Part 5 Search and Rescue 15 Towards the Establishment of a Search and Rescue Cooperation Mechanism in the South China Sea: Regulatory Framework, Challenges and Prospects  Yubing Shi 16 Understanding the Challenge: Mass Rescue Operations at Sea  Richard Button and Tom Gorgol 17 Models for Maritime Coordination in the South China Sea: Effective National-level Coordination  Brian Wilson Part 6 Sustainable Fisheries 18 Combating iuu<\sc>: the Driving Force behind Development of International Fisheries Law?  Kuan-Hsiung Wang 19 What’s in a Name: the Importance of Distinguishing between “Fisheries Crime” and iuu<\sc> Fishing  Kathryn Youel Page and Alexis J. Ortiz Part 7 Marine Biodiversity of Areas beyond National Jurisdiction (bbnj) 20 Negotiating a New Marine Biodiversity Instrument: Reflections on the Preparatory Phase from the Perspective of the European Union  Ronán Long and John Brincat 21 bbnj: Developments since Yogyakarta  J. Ashley Roach Index

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Book SynopsisLaunched in 1965, the Australian Year Book of International Law (AYBIL) is Australia’s longest standing and most prestigious dedicated international law publication. The Year Book aims to uniquely combine scholarly commentary with contributions from Australian government officials. Each volume contains a mix of scholarly articles, invited lectures, book reviews, notes of decisions by Australian and international courts, recent legislation, and collected Australian international law state practice. It is a valuable resource for those working in the field of international law, including government officials, international organisation officials, non-government and community organisations, legal practitioners, academics and other researchers, as well as students studying international law, international relations, human rights and international affairs. It focuses on Australian practice in international law and general international law, across a broad range of sub-fields including human rights, environmental law and legal theory, which are of interest to international lawyers worldwide.

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Book SynopsisThe driving force of the dynamic development of world legal history in the past few centuries, with the dominance of the West, was clearly the demands of modernisation – transforming existing reality into what is seen as modern. The need for modernisation, determining the development of modern law, however, clashed with the need to preserve cultural identity rooted in national traditions. With selected examples of different legal institutions, countries and periods, the authors of the essays in the two volumes Modernisation, National Identity and Legal Instrumentalism: Studies in Comparative Legal History, vol. I: Private Law and Modernisation, National Identity and Legal Instrumentalism: Studies in Comparative Legal History, vol. II: Public Law seek to explain the nature of this problem. Contributors are Judit Beke-Martos, Jiří Brňovják, Marjorie Carvalho de Souza, Michał Gałędek, Imre Képessy, Ivan Kosnica, Simon Lavis, Maja Maciejewska-Szałas, Tadeusz Maciejewski, Thomas Mohr, Balázs Pálvölgyi, and Marek Starý.Table of ContentsNotes on Contributors 1 Residential Right in the Course of Time: Changes in the Legal Institution of the Inkolat in the Bohemian Crown Lands  Jiří BrňovjákandMarek Starý 2 Legal Transfers and National Traditions: Patterns of Modernization of the Administration in Polish Territories at the Turn of the 19th Century  Michał Gałędek 3 National Modernization through the Constitutional Revolution of 1848 in Hungary: Pretext and Context  Imre Képessy 4 Restoring the Hungarian Historical Constitutional Order with a Coronation in 1867  Judit Beke-Martos 5 The Privy Council Appeal and British Imperial Policy, 1833–1939  Thomas Mohr 6 Direct Impact on Hungarian Migration Policy of the 1870 Agreement on Citizenship between the United States and Austria-Hungary (1880s–1914)  Balázs Pálvölgyi 7 Political Systems in Transition and Cultural (In)dependence: The Limits of a Legal Transplant in the Example of the Brazilian’s Court of Auditors Birth  Marjorie Carvalho de Souza 8 Constitutional Systems of Free European States (1918–1939)  Tadeusz Maciejewski and Maja Maciejewska-Szałas 9 Local Citizenship in the Croatian-Slavonian Legal Area in the First Yugoslavia (1918–1941): Breakdown of a Concept?  Ivan Kosnica 10 Nazi Law as Pure Instrument: Natural Law, (Extra-)Legal Terror, and the Neglect of Ideology  Simon Lavis Index

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Book SynopsisEuropean citizenship is facing numerous challenges, including fundamental rights and social justice considerations. These get amplified in the context of Brexit and the general rise of populism in Europe today. This book takes a representative selection of these challenges, which raise a multitude of highly complex issues, as an invitation to provide a critical appraisal of the current state of the EU legal framework surrounding EU citizenship. The contributions are grouped in four parts, dealing with constitutional developments posing challenges to EU citizenship; the limits of the free movement paradigm in the context of EU citizenship; EU citizenship beyond free movement; and, lastly, EU citizenship in the context of the outside world, including Brexit, the EEA and Eurasian Economic Union.Table of ContentsPreface Abbreviations Table of Cases Notes of Contributors 1 European Citizenship under Stress: Introduction   Nathan Cambien, Dimitry Kochenov and Elise Muir PART 1 EU Citizenship: Constitutional Challenges 2 EU Citizenship: Some Systemic Constitutional Implications   Dimitry Kochenov 3 Union Citizenship and Beyond   Hans Ulrich Jessurun d’Oliveira 4 EU Citizenship as a Means of Broadening the Application of EU Fundamental Rights: Developments and Limits   Katerina Kalaitzaki 5 Free Movement of Dual EU Citizens   David A.J.G. de Groot PART 2 Free Movement and Its Limits 6 The Court, the Legislature and the Co-Construction of a Status of Social Integration   Stephen Coutts 7 Life after the ‘Dano-Trilogy’: Legal Certainty, Choices and Limitations in EU Citizenship Case La   Moritz Jesse and Daniel William Carter 8 EU Citizenship, Access to “Social Benefits” and Third-Country National Family Members: Reflecting on the Relationship between Primary and Secondary Rights in Times of Brexit   Elise Muir 9 Residence Rights for EU Citizens and Their Family Members: Navigating the New Normal   Nathan Cambien 10 Distinguishing between Use and Abuse of EU Free Movement Law: Evaluating Use of the “Europe-route” for Family Reunification to Overcome Reverse Discrimination   Hester Kroeze 11 The Revised Posting of Workers Directive: Curbing or Ensuring Free Movement?   Piet Van Nuffel and Sofia Afanasjeva PART 3 EU Citizenship beyond Movement 12 The Pernicious Influence of Citizenship Rights on Workers’ Rights in the EU – The Case of Student Finance   Araceli Turmo 13 European Higher Education in the Context of Brexit   Sacha Garben 14 The Right to Participate in the European Elections and the Vertical Division of Competences in the European Union   Sébastien Platon 15 The European Citizens’ Initiative in Times of Brexit   Natassa Athanasiadou PART 4 Supranational Citizenship and the Outside World 16 The “Sale” of Conditional Citizenship: the Cyprus Investment Programme under the Lens of EU Law   Sofya Kudryashova 17 Member State Nationality, EU Citizenship and Associate European Citizenship   A.P. van der Mei 18 From Union Citizen to Third-country National: Brexit, the UK Withdrawal Agreement, No-Deal Preparations and Britons Living in the European Union   Gillian More 19 Free Movement of Persons in the EU v. in the eea: of Effect-Related Homogeneity and a Reversed Polydor Principle   Christa Tobler 20 The Free Movement of Persons in the Eurasian Economic Union – between Civis Eurasiaticus and Homo Oeconomicus   Bendikt Pirker and Kirill Entin

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Book SynopsisThe European Convention on Human Rights is now crucial to decisions to be taken by the military and their political leaders in ‘hard power’ situations – that is, classical international and non-international armed conflict, belligerent occupation, peacekeeping and peace-enforcing and anti-terrorism and anti-piracy operations, but also hybrid warfare, cyber-attack and targeted assassination. Guidance is needed, therefore, on how Convention law relates to these decisions. That guidance is precisely what this book aims to offer. It focuses primarily on States’ accountability under the Convention, but also shows that human rights law, used creatively, can actually help States achieve their objectives.Trade Review“[Peter Kempees’s] analysis of the case-law of the European Court of Human Rights contributes significantly to academic discussion on the scope of application of the European Convention on Human Rights in relation to governmental action of States Parties throughout the world. … All in all, it is a well-documented work.” Lt Col J.J.M. van Hoek LLM, Netherlands Military Law Review "...an important piece of legal scholarship on the law of the European Convention on Human Rights" Linos-Alexandre Sicilianos, President of the European Court of Human Rights (2019-2020).

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Book SynopsisConstitutions are a product of history, but what is the role of history in interpreting and applying constitutional provisions? This volume addresses that question from a comparative perspective, examining different uses of history by courts in determining constitutional meaning. The book shows that there is considerable debate around the role of history in constitutional adjudication. Are, for example, historical public debates over the adoption of a constitution relevant to reading its provisions today? If a constitution represents a break from a prior repressive regime, should courts construe the constitution’s provisions in light of that background? Are former constitutions relevant to interpreting a new constitution? Through an assessment of current practices the volume offers some lessons for the future practices of courts as they adjudicate constitutional cases. Contributors are: Mark D. Rosen, Jorge M. Farinacci-Fernós, Justin Collings, Jean-Christophe Bédard-Rubin, Cem Tecimer, Ángel Aday Jiménez Alemán, Ana Beatriz Robalinho, Keigo Obayashi, Zoltán Szente, Shih-An Wang, and Diego Werneck Arguelhes.Table of ContentsAcknowledgments List of Tables Notes on Contributors Introduction   Francesco Biagi, Justin O. Frosini and Jason Mazzone Part 1 Framing the Problem 1 History Limit or License in Constitutional Adjudication?   Mark D. Rosen 2 When History Requires the Use of History in Constitutional Adjudication   Jorge M. Farinacci-Fernós 3 Memory as Mantle Evil Pasts and Judges’ Power in Germany and South Africa   Justin Collings Part 2 Historical Precedents and Inter-constitutional Interpretation 4 Comparing Constitutional Historicities The Case of Precedents in Canada and the United States   Jean-Christophe Bédard-Rubin 5 Inter-constitutional Interpretation A Case Study of the Articles of Confederation   Cem Tecimer Part 3 A Matter of Narratives 6 Janus’ Third Face? The Spanish Constitutional Court at the Crossroads of History   Ángel Aday Jiménez Alemán 7 Competing Narratives The Use of Historical Arguments in Constitutional Interpretation in Brazil   Ana Beatriz Robalinho 8 Manipulating Constitutional, Legislative and Judicial History Incremental Judicial Activism in the Japanese Supreme Court   Keigo Obayashi Part 4 New Democracies and Illiberal Regimes 9 How Not to Use History in Constitutional Interpretation The Aborted Resurrection of the Historical Constitution in Hungary   Zoltán Szente 10 Using the Authoritarian Past for Constitutional Interpretation in New Democracies The Example of the Taiwan Constitutional Court   Shih-An Wang  Conclusion Which History, Whose Past?   Diego Werneck Arguelhes Index

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Book SynopsisThis book argues that a view has taken root in Africa, which equates state-secularism to the aggressive removal of religion from the public sphere or even state ambivalence towards religious affairs. This view arises from a misguided interpretation of the practice of state-secularism particularly in France, Turkey and the US, which understanding is ill-suited for the sub-Sahara Africa’s state-religion because the region boasts of at least three major religious traditions, African religion, Islam and Christianity, and blanket condemnation of public manifestation of religion or ambivalence towards it may offend the natural flourishing of this trinity and more. The contribution holds that most applications of state-secularism in Kenya, Nigeria and Uganda favour the Christian faith, which during its tumultuous experiences in Europe survived the enlightenment, the reformation and like experiences socialised to co-exist with what are now called secular states. Additionally, due to the long history of Christendoms in Europe, Christian principles penetrated the colonial legal systems that were bequeathed to Africa at independence and the sustenance of the colonial legacy means that the Abrahamic faith has an upper hand in the state-religion relations’ contest. The obvious loser is African religion which has suffered major onslaughts since the colonial days.Table of ContentsAfrica and the Decolonisation of State-Religion Policies  John Osogo Ambani Abstract Keywords  Preface  Part 1: State-Religion Relations  Part 2: A Theoretical Framework for the African Triple Heritage  Part 3: African Case Studies in the Secular State Conundrum  Part 4: The Right to Freedom of Religion: Case Study of the Treatment of Religion in Educational Institutions  Part 5: Conclusion and Way Forward

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Book SynopsisLegal Challenges in the New Digital Age addresses a wide range of legal issues related to emerging technologies. These technologies pose prominent legal challenges, in particular, how to wedge new phenomena into old frameworks; whether we can and should delegate responsibilities to technologies and how to cope with newly created powers of manipulation. Edited by Ana Mercedes Lopez Rodriguez, Michael D. Green and Maria Lubomira Kubica, the book’s sixteen chapters are written by highly qualified international practitioners and academics from different jurisdictions. Familiarity with the intricacies of emerging technologies is essential for judges, practitioners, legal staff, business people and scholars. This book’s combination of highly thought-provoking topics and in-depth analysis will prove indispensable to all interested parties.Table of ContentsForward List of Figures and Tables PART 1 Existing Legal Concepts And Disruptive Technologies 1 Tort Law and New Technologies   Eugenia Dacoronia 2 Geo-Blocking and EU Competition Law in the Digital Era   Michele Messina 3 (In)fallible Smart Legal Contracts   Manuel A. Gómez 4 An Analysis on the Application of the UNCITRAL Model Law on Electronic Transferable Records on Contract Automation and Metadata   Jurij Lampic & Irene Ng (Huang Ying) 5 The Electronic Devices Used for Testamentary Disposition Under Polish Law   Wojciech Banczyk 6 EU Customs Regulation, Patent Assertion Entities and the New Surge of Abusive Practices in Europe   Matteo Dragoni PART 2 The Impact Of Digitalization On Privacy And Fundamental Rights 7 General Data Protection Regulation, Fundamental Rights and Private International Law   Giulia Rossolillo 8 Legal and Ethical Implications of eHealth Big Data———A Comparative Perspective between Japan and Catalonia   Albert Ruda 9 Artificial Intelligence in Criminal Courts  Opportunity or Threat?   Luca Lupària Donati 10 Coping with Identity Theft and Fear of Identity Theft in the Digital Age   Naci Akdemir 11 Algorithmic Dispute Resolution  Will the Decision of a Robo-Arbitrator Fall under the New York Convention?   Rafael Carlos del Rosal Carmona 12 Social Media as Monitoring Tools in the Workplace  A Threat to Employees’ Right to a Private Life?   Stefania Casiglia PART 3 Implementing New Technologies In The Legal Field 13 Blockchain and Its Impact on Human Rights   Ana Mercedes López Rodríguez 14 The Spoken Word, the Written Word and the Digital Word  Discursive Discontinuities and Change of Legal Canons   Flávia Noversa Loureiro 15 Personalization of Consumer Contracts—Should We Personalize Interpretation Rules?   Katarzyna Południak-Gierz 16 The Fate of Law as Technology and Technology as Legal Reasoning  The Red Queen Effect in Smart Cities   María Luisa Gómez Jiménez Index

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Book SynopsisA Geo-Legal Approach to the English Sharia Courts: Cases and Conflicts adopts a new methodological perspective that combines Comparative Law with Geopolitics to understand the phenomenon of the English ‘sharia courts’. This term is used as a geopolitical representation of specific Islamic ADR institutions. The geo-legal analysis illustrates the competition of the legal systems involved and brings you in the middle of the related conflict, where (official and unofficial) legal rules are used by various actors to defend their ideas of Law and implement their strategies. Accordingly, the geo-legal operational analysis helps assess the possible changes occurring in the relationship between the legal systems and their substratum of values. Funding for the research associated with this book was provided by the University of Campania “Luigi Vanvitelli” – Dept. of Political Science and by the Italian Ministry of University and Research through the National Project (PRIN 2017 n. 20174EH2MR) on “International Migrations, State, Sovereignty, Human Rights: open legal issues” directed by Prof. Angela Di Stasi and Prof. Ida Caracciolo.Table of Contents

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Book SynopsisThis book places under scrutiny for the first time, whether, and how, the United Nations Human Rights Council actually contributes to the protection of human rights in the face of pervasive gross violations world-wide. It finds that the Council does little of preventive protection, some mitigatory protection, and little remedial or compensatory protection. The Council’s response to situations of gross violations depends on the political alignments within its membership for each situation. The Council gives priority to cooperation and dialogue over principled denunciations of gross violations. It is not an organ of justice, but in some instances it is an organ for justice, inasmuch as it addresses the structural causes of violations. Much useful fact-finding takes place under the auspices of the Council, and it does contribute to the progressive development of international law.Table of ContentsChallenges of Protection Foreword Preface Introduction 1 Promoting Protection  1 Introduction  2 The Universal Periodic Review  3 Standard-Setting  4 Cooperation with National Human Rights Institutions  5 Business and Human Rights  6 Indigenous Populations  7 Minorities  8 Slavery and Slavery-Like Practices  9 Racism and Racial Discrimination  10 Human Rights Defenders  11 Studies  12 Human Rights Education and Training  13 Country Rapporteurs, Thematic Rapporteurs and Working Groups  14 World Campaign on Human Rights  15 Cooperation with Related UN Organs  16 Cooperation with Regional Human Rights Bodies  17 Conclusion 2 Universality  1 Introduction  2 The Universal Periodic Review  3 Philosophical Universality  4 Universality of Human Rights under International Law: The International Bill of Human Rights  5 Challenges to Universality  6 Defending Universality  6.1 The Democratic Test Of Universality  6.2 The Bases of Universality  6.3 Challenges of Implementation  6.4 Normative Universality  6.5 Universality in the UN Human Rights Council: The upr Process  6.6 Political Universality  6.7 The Universality of International Law  6.8 Populism and Universality  6.9 Global Poverty and Universality  6.10 Gross Violations of Human Rights and Universality  6.11 Democratic Universality/Peoples’ Universality  6.12 Universality as an Idea  6.13 Universality as a Goal  6.14 Universality as a Normative Concept  7 Conclusion 3 Protection  1 Introduction  2 Efforts for International Protection  3 The Human Rights Council  4 High Commissioner’s Updates to the Human Rights Council on Situations of Concern  5 Protection Activities of Special Procedures of the Council  6 Conclusion 4 Prevention  1 Introduction  2 Pronouncements of the Council on Prevention  3 Preventive Actions of Special Procedures of the Council  4 Early Warning from the UN High Commissioner  5 Tackling Root Causes of Violations  6 Conclusion 5 Urgent Action  1 Introduction  2 Special Sessions of the Council  3 Urgent Actions by the President of the Council  4 Urgent Actions by the High Commissioner at the Request of the Council  5 Conclusion 6 Good Offices  1 Introduction  2 Urgent Communications to Governments  3 Confidential Complaints Procedure  4 Good Offices by the President of the Human Rights Council  5 Conclusion 7 Fact-Finding  1 Introduction  2 Principles of Fact-Finding  2.1 Do No Harm  2.2 Independence  2.3 Impartiality  2.4 Transparency  2.5 Objectivity  2.6 Confidentiality  2.7 Credibility  2.8 Visibility  2.9 Integrity  2.10 Professionalism  2.11 Consistency  3 The Special Procedures and Commissions of Inquiry  4 Conclusion 8 Redress  1 Introduction  2 Principles of Redress  3 Right to Truth  4 Expressions of Concern Over, or Condemnation of Gross Violations  5 Accountability  6 Transitional Justice  7 Evaluation  8 Conclusion 9 Justice  1 Introduction  2 The Decline of Democracy in the World  3 The Decline of Human Rights Justice in the World  4 The Idea of Justice in Philosophical Literature  5 The Idea of Justice in the International Bill of Human Rights  5.1 Equal Enjoyment of Enumerated Rights  5.2 Non-Discrimination  5.3 Discrimination Versus Distinction  5.4 Affirmative Action  5.5 General Comment 4/13 of the Human Rights Committee (Gender Equality)  5.6 The Beijing World Conference on Women’s Rights (1995)  5.7 Equitable Life Chances  6 The Human Rights Council’s Contributions to the Global Quest for Justice  7 The Human Rights Council as a Forum for Seeking and Promoting Global Justice  7.1 Global Hunger  7.2 Widespread Lack of Access to Medicine  7.3 Widespread Lack of Access to Safe Drinking Water and Sanitation  7.4 World-Wide Discrimination Against Women  7.5 Child, Early and Forced Marriage in Times of Crisis, Including the covid-19 Pandemic  7.6 Pervasive Gross Violations of Human Rights  7.7 Afro-Descendants  7.8 lgtbq s  7.9 Albinism  8 Conclusion 10 Jurisprudence  1 Introduction  2 The Architecture of International Law: Principles of the UN Charter  3 Normative Instruments: Treaties and Declarations  4 Principles on Human Rights and the Environment  5 Human Rights and Climate Change  6 The Right to Peace  7 Promotion of a Democratic and Equitable International Order  8 Human Rights: International Cooperation and International Solidarity  9 Guiding Principles on Business and Human Rights  10 National Infrastructure  11 Protection of Human Rights While Countering Terrorism  12 Rights to Freedom of Peaceful Assembly and of Association  13 Protection from Arbitrary Detention  14 Protection of Human Rights Defenders  15 Right to Truth  16 Transitional Justice  17 Protection of Civilians in Armed Conflict  18 Right to Food  19 Human Rights and Access to Safe Drinking Water and Sanitation  20 Access to Medicine  21 Guiding Principles on Extreme Poverty and Human Rights  22 Rights of Peasants  23 The Human Rights of Older Persons  24 Basic Principles and Guidelines on Development-Based Evictions and Displacement  25 Trafficking in Persons  26 Mercenarism  27 Conclusion Conclusion Bibliography Index

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Book SynopsisThis book is an essential contribution to understanding Russian law for English speakers. In a time when the energy markets in Europe are changing away from Russian dependence on oil and gas, Dr Svendsen explains what the legal consequences will be if we would experience cross-border harm as a result of an oil spill from offshore installations on the Norwegian and the Russian side of the sea border in the Barents Sea. This book examines Russian and Norwegian rules governing liability, choice-of-law, recognition and enforcement, damage, third-party losses, environmental harm, and valuation of environmental harm.Table of ContentsList of Figure part 1 Introduction 1 Introduction  1.1 Introduction  1.2 Background  1.3 The Absence of International Legal Agreements Regulating Oil Pollution Damage from Offshore Subsoil Activities  1.4 The Barents Sea  1.5 Limitations and Assumptions throughout the Book 2 Sources of Law in Norway and Russia  2.1 Introduction  2.2 Sources of Law – Norway  2.3 Sources of Law – Russia  2.4 Some Comments on Legal Reasoning  2.5 Materials Used 3 Principles and Considerations in Norwegian and Russian law  3.1 Introduction  3.2 The Use of the Terminology ‘Legal Principle’ in This Book in Relation to Norwegian and Russian Law  3.3 The International Environmental Polluter Pays Principle – from an Economic to a Multi-version Principle  3.4 Common Consideration in Norwegian and Russian Law  3.5 Norwegian National Considerations with Respect to Chapter 7 of the Petroleum Act  3.6 Russian National Considerations  3.7 Comparative Notes  3.8 Conclusions 4 Liability for Pollution Damage in the Barents Sea  4.1 Introduction  4.2 Liability for Pollution Damage in Norway  4.3 Liability for Pollution Damage in Russia part 2 Procedural Law Issues: Choice-of-Law, and Recognition and Enforcement of Foreign Judgments 5 Choice of Law Rules in the Petroleum Act and the Civil Code  5.1 Introduction  5.2 Two Cross-Border Pollution Scenarios  5.3 A Harmed Russian Party Filing a Claim for Compensation in a Norwegian Court for Harm Inflicted to the Russian Party, When Located in the Russian Part of the Barents Sea, by a Norwegian Company Located in the Norwegian Part of the Barents Sea  5.4 A Harmed Norwegian Party Filing a Claim for Compensation in a Russian Court for Harm Inflicted to the Norwegian Party Located in the Norwegian Part of the Barents Sea by a Russian Company Located in the Russian Part of the Barents Sea  5.5 Conclusion of Choice of Law 6 Recognition and Enforcement of Foreign Judgments in National Courts Absent an International Agreement (Enforcement of Norwegian Judgments in Russian Courts and Russian Judgments in Norwegian Courts)  6.1 Introduction  6.2 European Recognition and Enforcement Regimes of Foreign Judgments in Civil and Commercial Matters  6.3 Norwegian Legal Approach to Recognition and Enforcement of Foreign Judgments in Civil and Commercial Matters  6.4 Russian Legal Approach to Recognition and Enforcement of Foreign Judgments in Civil and Commercial Matters  6.5 Conclusion of Recognition and Enforcement of Foreign Judgments Part 3 Substantive Law Issues: Examining Compensability through the Concept of Damage, Losses Suffered by Third Parties, and Harm to the Environment and Its Valuation and Calculation 7 The Definition and Understanding of the Norwegian Concept of “Damage” under the Petroleum Act and the Russian Concept of “Harm” under the Federal Continental Shelf Law and the Federal Environmental Protection Law  7.1 Introduction  7.2 Norwegian Law  7.3 Russian Law  7.4 Comparative Analysis  7.5 Conclusion of Chapter 7 8 Compensability of Losses Suffered by Third Parties: Establishing Protection in Delict Law and Limitation of This Liability through Causation  8.1 Introduction  8.2 Historical Prelude  8.3 Pure Economic Loss and Losses Suffered by Third Parties  8.4 Norwegian Law: the Establishment of Protection in Delict Law and Limitation of Liability through Proximity in Causality and Balancing of Interests  8.5 Russian Law – the Concept of “Unreceived Income”  8.6 Comparative Analysis  8.7 Conclusion on Losses Suffered by Third Parties 9 Compensability of Harm to the Marine Natural Environment Caused by Petroleum Spills  9.1 Introduction  9.2 Values Attributable to the Environment  9.3 Norwegian Law  9.4 Russian Law  9.5 Comparative Analysis  9.6 Conclusion of Chapter 9 10 The Valuation and Calculation of Compensable Damage to the Environment  10.1 Introduction  10.2 The Primary Valuation and Calculation Methods  10.3 The Norwegian Approach to Restoration and Replacement Costs  10.4 The Russian Approach: Market Valuation and Mathematical Formulas  10.5 Comparative Analysis  10.6 Conclusion 11 Conclusions and Policy Recommendations  11.1 Introduction  11.2 Conclusions and Summary of the Book  11.3 Policy Recommendations Annexes Bibliography Index

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Book SynopsisWhat makes the relationship between Switzerland and the EU so challenging? For both parties, mutual relations are of crucial importance, not least economically. As a result of the Swiss voters’ rejection of the European Economic Area 30 years ago, there is at present a large number of agreements that provide for Switzerland's partial participation in the EU's internal market as well as other matters. At the same time, there has now for more than a decade been an increasing degree of institutional and legal uncertainty. The present volume offers an inventory of different sides of this special relationship, which is interesting also in a comparative context.Table of ContentsPreface Acknowledgements List of Figures Abbreviations Notes on Contributors – Excluding the Editors, Marc Maresceau and Christa Tobler Introduction Switzerland and the EU: A Challenging Relationship   Marc Maresceau and Christa Tobler 1 The Policy of Autonomous Adaptation of Swiss Law to EU Law   Matthias Oesch and Mattia Brugger 2 The Agreement on the Free Movement of Persons From the (Almost) Complete Integration of EU acquis on Social Security Coordination to the Absence of Integration of Directive 2004/38   Pauline Melin 3 Sectoral Bilateralism Lessons from the Case Law of the Court of Justice of the European Union   Peter Van Elsuwege 4 The Swiss Posted Workers Act and Free Movement of Services between Switzerland and the European Union   Kurt Pärli 5 covid-19, Switzerland and the EU Pandemic-Related EU Action and Its Legal Effect on Switzerland as Compared to the eea efta States   Christa Tobler 6 Switzerland’s Structural Participation in EU Agencies   Merijn Chamon 7 The Case-by-case Cooperation between the EU and Switzerland in Foreign Policy, Security and Defence   Christophe Hillion 8 The Road to Tax Transparency in Switzerland   Hans-Joachim Jaeger and Katharina Manz 9 A Comparison between the Swiss Cohesion Payments and the eea and Norway Grants   Benedikt Pirker 10 The Shelved Institutional Agreement eu-ch from a Political Science Perspective   René Schwok 11 Switzerland and the EU The Failure of the Institutional Agreement from a Legal Perspective   Christine Kaddous 12 The Federal Council’s Suggested Sectoral Approach Post-26 May 2021 and the Future of EU-Swiss Trade Relations   Michael Hahn 13 Switzerland-UK Trade Relations: A Future Planned by the Past? An Overview of the Trade Agreement between Switzerland and the United Kingdom and Related Agreements   Georges Baur Index

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Book SynopsisWhat is the status of indigenous religious rights in the world today? Despite important legal advances in the protection of indigenous religious beliefs and practices at the international and national levels, there are still many obstacles to the full implementation of these provisions. Using a unique large-scale comparative approach, this book aims to identify the fundamental issues that characterize the law of indigenous religions in several countries, as well as certain avenues that may prove useful in state implementation of the provisions of the United Nations Declaration on the Rights of Indigenous Peoples regarding practice, promotion, transmission, protection, and access to spiritual heritage.Table of ContentsForeword Introduction  Claude Gélinas, Sébastien Lebel-Grenier and Raphaël Mathieu Legault-Laberge The Pachamama, the Trojan Horse of an Indigenous Ontological Diplomacy at the Convention of Biological Diversity?  Ingrid Hall Spiritual, Religious or Cultural? Religion and Sámi Human Rights in the Nordic Countries  Helge Årsheim Indigenous Religious Rights in India  Virginius Xaxa Australia Has Failed to Protect the Religious Rights of Its Indigenous People  Ernst Willheim Kanak Custom and Ancestral Culture in Colonial Context  François Féral The Ainu Struggle for Sovereignty and Religious Freedom  Takeshi Kimura Indigenous Religious Rights in the United States  Allison M. Dussias The Colonial Overtones of Indigenous Religious Rights in Canada  Claude Gelinas The Fundamental Right to Freedom of Religion for Indigenous Peoples in Chile: Intersections with Territorial Rights and Cultural Integrity  Leslie Cloud Exploring the Historical Impact of Colonialism on Indigenous Religious Rights in Nigeria  Abiodun Akeem Oladiti Recognition and Denial of Indigenous Religious Rights in East and Central Africa  Guy Bucumi Indigenous Religious Rights in Taiwan: The Invisibility of Animism in Modern State Law  Scott Simon Integration or Separation? Religious Freedom in Post-Authoritarian Indonesia:The Case of the Indigenous Kaharingan Religion in Central Kalimantan  Mirza Satria Buana From Marginalisation to Self-determination: The Long Walk of First Nations’ Religious Rights in Bolivia  Raphaël Mathieu Legault-Laberge Index

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Book SynopsisThough European administrative laws have gained global significance in the last few decades, research which provides both theoretical analysis and original empirical research has been scarce. This book offers an important account of the evolution of judicial review and administrative procedure legislation, using a factual analysis to shed light on how the different legal systems react to similar problems. Discussing the concept of a ‘common core’, Giacinto della Cananea reveals the commonalities in, and differences between, the foundational assumptions of European administrative adjudication and rule-making.Table of ContentsPreface 1 The Development of Administrative Law: Fact and Theory 1 Two Visions of Administrative Law 2 Public Administration without Administrative Law 3 Administrative Law as a Defining Aspect of the New State of the World 4 The Transformation of Administrative Law 5 A New Comparative Inquiry 6 Limits to the Inquiry 7 Structure of the Inquiry Part 1 A Diachronic Comparison 2 Judicial Review of Administration: Institutional Design 1 England and France: Ideal-types and Prototypes 2 The Reception of the English Prototype: Belgium and Italy 3 The Reception of the French Prototype: Italy and Belgium 4 The Austro-German Prototype 5 French Systematics in Germany 6 German Systematics in Italy 7 Beyond the State: Judicial Remedies in the European Communities 3 The Judicial Construction of General Principles (1890–1910) 1 An Empirical Analysis 2 Administrative Litigation: Similar Problems 3 Devising Solutions: Legality and Procedural Fairness 4 Devising Solutions: Government Liability 5 The Role of Judge-Made Law and the Place of Legal Theory 6 The Emergence of Common Principles 4 Sowing the Future: Austrian Administrative Procedure Legislation 1 Early Views on the Codification of Administrative Procedure 2 The Austrian Turn: Background 3 The Austrian Turn: Principles 4 An Area of Agreement between Legal Systems 5 A Case of Diffusion 6 The Wider Reach of Austrian Ideas 5 The Development of Administrative Procedure Legislation 1 Moving towards Administrative Procedure Legislation 2 Socialist Legal Systems and the Austrian Legacy 3 Spanish Legislation and Its Diffusion in Latin America 4 The Scandinavian Standard of Fair Procedure 5 Types of States and Administrative Procedure Legislation Part 2 A Synchronic Comparison 6 Commonality and Diversity in Administrative Procedure Legislation 1 The Diversity of Constitutional Foundations 2 The Heterogeneity of Administrative Procedure Legislation 3 An Area of Agreement: Administrative Adjudication 4 The Closest Things to Invariants: Hearings 5 The Closest Things to Invariants: Giving Reasons 6 Diversity: Rulemaking 7 A Factual Analysis: Adjudication 1 Hypothetical Cases 2 Freedom from Bias 3 The Unfair Dismissal of a Civil Servant 4 A License Revocation Inaudita Altera Parte 5 Administrative Detention without Reasons 6 Consultation: The Role of Experts 7 An Area of Agreement 8 A Factual Analysis: Rulemaking 1 Variety of Administrative Rules 2 Standardless Discretion? 3 Consultation before Policy Change 4 Partially Unpublished Rules 5 An Unexpected Area of Agreement 9 Governmental Wrongdoing 1 A Worst-Case Scenario 2 Further Consequences of Procedural Unfairness in Adjudication 3 Contracts: The Unlawful Exclusion of a Tenderer 4 The Violent Police Officer 5 Conclusion Part 3 Commonality and Diversity: An Evolving Relationship 10 Explaining Diversity 1 The Causes of Commonality and Diversity 2 Context Matters: History 3 Context Matters: Mentalités in Public Law 4 Policy Considerations and Change 5 Diverging Traditions: Rules and Legal Formants 6 The Legal Relevance of National Traditions 11 Explaining Commonality 1 The Legacy of ius commune: A Qualified View 2 The ‘Nature of Things’ 3 Legal Transplants: Authority, Prestige, and Quality 4 General Principles 5 Legal Harmonization 6 Institutional Isomorphism 7 The Growing Impact of Common Standards 12 The ‘Common Core’ of Administrative Laws: Concept, Nature, and Extent 1 Factual Analysis and Theory Development 2 The Common Core: An Overview of the Argument to Come 3 The Common Core: Concept and Issues 4 A Dynamic View of the Common Core 5 The Nature of the Common Core 6 The Extent of the Common Core 7 The Variety of Uses of the Common Core Index

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Book SynopsisThe trend of measuring performances is global and pervasive. We all live in quantified societies, in which performances in an ever-growing array of fields–from education to health, work to credit, justice to consumption–are assessed and governed through quantitative techniques. While the disruption brought by the quantitative turn has been widely studied by social scientists, legal research on the issue is minimal. This book aims to fill the gap. The essays herein collected explore how performance measurements interact with the law in different regions and sectors, which legal effects they produce, and for whose benefit.Table of ContentsList of Figures and Tables Notes on Contributors 1 Quantification of Performance as a Regulatory Technique: An Introduction   Mauro Bussani, Sabino Cassese and Marta Infantino Part 1 Justice and Education 2 Revisiting ‘Justice in Numbers’ in Brazil: Quantified Justice, Managerial Judges, and Numeroids as a Regulatory Technique   Pedro Rubim Borges Fortes 3 Performance-Based Evaluation in Mexico’s Federal Administrative Justice Tribunal and the Federal Judiciary Power: A Comparison   Luis José Béjar, Juan Antonio Casanovas and Carlos A. Villanueva 4 Judicial Performance Index in India: Charting a New Course   Manjeri Subin Sunder Raj and Chiradeep Basak 5 Performance Assessment in Courts – the Swiss Case   Andreas Lienhard 6 Admission Algorithms for Affirmative Action in Higher Education: The South African Experience   Viyaleta Farysheuskaya and Patrizio Piraino 7 Quantification and Parameterization of Legal Research: The Case of Poland   Andrzej Jakubowski Part 2 National Policy Making 8 Algorithmic Decision-Making and Public Sector Accountability in Africa - New Challenges for Law and Policy   Raenette Gottardo 9 Governance and Quantification of Performance in China   Ivan Cardillo 10 Use and Abuse of Quantitative Methodology for Policy Making in Japan   Tatsuhiko Inatani and Masahiko Kinoshita 11 Measuring Human Rights Performance in the UK: Liberalism, Communitarianism, and the Equality and Human Rights Commission’s ‘Drunkard’s Search’   David McGrogan Part 3 Transnational and International Market-Related Activities 12 Profiling in Algorithm-Based Decisions: An African Perspective   Salvatore Mancuso and Livio Corselli 13 Trust in an ‘Omnimetric Society’? Reputational Systems in Platforms as Tools for Assessing Contractual Performance and Applying Remedies   Teresa Rodríguez de las Heras Ballell 14 Performance Measurements in Compliance with Corporate Social Responsibility Obligations   Lukas Heckendorn Urscheler 15 The Role of International Organizations in the Production of Legal Metrics   Kevin E. Davis 16 Quantification of Performance as a Regulatory Technique: A Comparative Appraisal   Mauro Bussani, Sabino Cassese and Marta Infantino Detailed Table of Contents Index

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Book SynopsisThis volume offers an extensive introduction to Western legal traditions from antiquity to the twentieth century. Drawing from a variety of scholarly writings, both in English and in translation, thirteen leading scholars present the current state of western legal history research and pave the way for new debates and future study. This is the ideal sourcebook for graduate students, as it enables them to approach the key questions of the field in an accessible way. Contributors are: Aniceto Masferrer, C.H. (Remco) van Rhee, Seán P. Donlan, Stephan Dusil, Gerald Schwedler, Jean-Louis Halpérin, Jan Hallebeek, Agustín Parise, Heikki Pihlajamäki, Dirk Heirbaut, Bernd Kannowski, Adolfo Giuliani, Olivier Moréteau, and Jacques Vanderlinden.Trade ReviewThe press about volume 1 in the series: "[The book] succeeds as an excellent point of entry to what at times can seem like a highly complex subject. [..] [The editors] and their fellow contributors have undoubtedly got the new series off to the strongest possible start." – Warren Swain, The Edinburgh Law ReviewTable of ContentsNotes on Contributors Western Legal Traditions: An Introduction   Aniceto Masferrer, C.H. van Rhee, Seán P. Donlan and Cornelis Heesters 1 Antiquity (753 bc–565 ad)   Jan Hallebeek 2 Early Middle Ages (500–1100)   Stephan Dusil, Bernd Kannowski and Gerald Schwedler 3 High and Late Middle Ages (1100–1500)   Dirk Heirbaut and Heikki Pihlajamäki 4 From Ius Commune Multi-normativity to a Sovereign Legislator (1500–1650)   Adolfo Giuliani 5 1650–1775   Jean-Louis Halpérin 6 Revolutionary Period and Nineteenth Century (1776–1900)   Aniceto Masferrer and C.H. van Rhee 7 Contemporary Period (1900–Present)   Olivier Moréteau, Agustín Parise and Jacques Vanderlinden† Index

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Book SynopsisThis volume offers an extensive introduction to Western legal traditions from antiquity to the twentieth century. Drawing from a variety of scholarly writings, both in English and in translation, thirteen leading scholars present the current state of western legal history research and pave the way for new debates and future study. This is the ideal sourcebook for graduate students, as it enables them to approach the key questions of the field in an accessible way. Contributors are: Aniceto Masferrer, C.H. (Remco) van Rhee, Seán P. Donlan, Stephan Dusil, Gerald Schwedler, Jean-Louis Halpérin, Jan Hallebeek, Agustín Parise, Heikki Pihlajamäki, Dirk Heirbaut, Bernd Kannowski, Adolfo Giuliani, Olivier Moréteau, and Jacques Vanderlinden.Table of ContentsNotes on Contributors Western Legal Traditions: An Introduction   Aniceto Masferrer, C.H. van Rhee, Seán P. Donlan and Cornelis Heesters 1 Antiquity (753 bc–565 ad)   Jan Hallebeek 2 Early Middle Ages (500–1100)   Stephan Dusil, Bernd Kannowski and Gerald Schwedler 3 High and Late Middle Ages (1100–1500)   Dirk Heirbaut and Heikki Pihlajamäki 4 From Ius Commune Multi-normativity to a Sovereign Legislator (1500–1650)   Adolfo Giuliani 5 1650–1775   Jean-Louis Halpérin 6 Revolutionary Period and Nineteenth Century (1776–1900)   Aniceto Masferrer and C.H. van Rhee 7 Contemporary Period (1900–Present)   Olivier Moréteau, Agustín Parise and Jacques Vanderlinden† Index

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Book SynopsisIndependence and impartiality are key to any judicial process. The dualistic nature of arbitration, i.e., being judicial and contractual, raises the question of how to set the standard of independence and impartiality in arbitration. On the one hand, arbitrators are decision makers similar to judges. On the other hand, they solve disputes outside the courtroom and are (often) appointed by the parties due to their individual expertise.Against this backdrop, this book analyses the state of play of independence and impartiality. It provides an overview of the current status of independence and impartiality applied in international commercial arbitration, focusing on case law from France, Germany, Switzerland, the United Kingdom, and the United States. The core themes are possible grounds for finding dependence and partiality and their streamline in theoretical standards of independence and impartiality. Additionally, consequences of independence and impartiality are addressed, including the obligation to disclose.This book is useful for practitioners and scholars alike. It may help counsels preparing a challenge, arbitrators defining their obligation to disclose, and scholars analysing independence and impartiality on a more general basis.Table of ContentsList of Abbreviations; Acknowledgements; Introduction; 1 Introduction to International Commercial Arbitration; 2 Applicable Laws, Rules, and Guidelines; 3 Overview of the Compared Legal Systems; 4 Conflicts of Interest; 5 Other Potential Grounds for Challenge or Annulment Based on Dependence and Partiality; 6 The Applicable Standard of Independence and Impartiality; 7 Consequences; 8 Conclusion and Outlook; Bibliography; Table of Cases; Index

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Book SynopsisThis book provides a detailed analysis of the different principles that shape the constitutional background of campaign finance law. Through three indicative country specific examples, the author examines legislation and jurisprudence that reflect such principles and demonstrate the common and different approaches in this upcoming field of law as driven by different constitutional traditions.This is the first time in legal scholarship that such an analytical effort is made to draw universal conclusions on campaign finance law principles. The US, the UK and Greece represent different jurisdictional examples of regulatory evolution in the effort to control the effect of money in politics. The author achieves to set the foundations of a practical and academic debate on global campaign finance reform.The book is a useful tool for public law scholars, political scientists as well as politicians and legal practitioners who are faced with campaign finance regulation and enforcement questions in the three jurisdictions and globally.Table of ContentsChapter 1 Introduction; Chapter 2 The Constitutional Framework of Campaign Finance Regulation: Fundamental Principles; Chapter 3 Campaign Finance Regulation in the U.S.; Chapter 4 Campaign Finance Regulation in the U.K.; Chapter 5 Campaign Finance Regulation in Greece; Chapter 6 Comparative Assessment; Chapter 7 Towards Campaign Finance Reform; List of Cases

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Book SynopsisComparative Constitutional Justice adopts an innovative approach to constitutional justice. From a methodological perspective, it assumes that it is impossible to apply an absolute criterion of classification, which depends on the purposes comparative scholars aim to achieve when delivering their own taxonomies. A broad definition of constitutional justice is adopted, which revolves around the following taxonomy: 1) the legality of norms, 2) the conformity of actors’ behaviours with the distribution of sovereign powers and 3) the compliance with international covenants on human rights. This tripartite classification complements a further criterion based on the graduation in the intensity of this review. This indeed ranges from a minimum scrutiny limited to legislation (‘nomocratic review’) to a maximum scrutiny encompassing all state activities (‘pantocratic review’). The proposed classification will provide readers with a critical toolbox when it comes to examining the pluralism which characterises the systems of constitutional adjudication around the world.Table of ContentsList of Abbreviations; 1 Defining Comparative Constitutional Justice; Part I Constitutional Review: The Legality of Norms; 2 Prototypes of Constitutional Litigation; 3 Dissemination, Alteration and Deformation of Constitutional Justice; 4 Variables of Constitutional Justice; Part II Pantocratic Review and the Distribution of Sovereign Powers; 5 Judicial Review on Federal Grounds; 6 Judicial Review and Sovereign Powers; 7 Constitutional Adjudicators and Frame of Government; Part III Human Rights Protection and Democratic Difficulties; 8 Varieties of Judicial Review: Constitutional, Treaty-Based and Transnational; 9 Almighty Judges? The Legitimacy of Constitutional Review

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Book SynopsisThis collection analyses the regulatory aspects of harmful interference faced by those entities operating space communication and broadcasting. While technology reacts to this international phenomenon with the development of continuously improving technological systems for preventing and combating harmful interference, its international regulatory and legal framework develops at a much slower pace. Issues discussed include the increasing deterioration of signals from broadcasting and communication satellites, including cases of intentional interference known as `jamming'; the human rights balance between freedom of expression and protection from hate speech; the efficacy of the current regulatory system and the legal consequences of non-compliance; the role of national authorities, and supranational bodies such as the EU and UN. The contributors include experts drawn from international and national academia, the ITU, national regulatory authorities and operators to present an internatiTable of ContentsIntroduction, Mahulena Hofmann. Part I Harmful Interference in the Context of the ITU Framework: 'Harmful interference' and the ITU, Francis Lyall; ITU and harmful interference prevention, Mitsuhiro Sakamoto; Dealing with harmful interference: the Protostar case, Elina Morozova and Yaroslav Vasyanin; Radio frequency interference in the Earth Exploration Satellite Service: the case of the European Space Agency's SMOS mission, Alexander Soucek; Contractual responses to loss of satellite based services, Lesley Jane Smith. Part II Harmful Interference in the Context of Space Law: The 'space side' to 'harmful interference' - evaluating regulatory instruments in addressing interference issues in the context of satellite communications, Frans von der Dunk; Harmful interference in telecommunications under international and national space law, Jean-Francois Mayence. Part III Harmful Interference in the Context of European Law: European law as an instrument for avoiding harmful interference, Gerry Oberst; The European Commission's proposal for a 'connected continent', Max Spielmann. Part IV Harmful Interference from the Perspective of National Law: Harmful interference from the Netherlands Radiocommunication Agency perspective, Johan Kroon; Satellite harmful interference: a U.S. Telecom perspective, Justin (Gus) Hurwitz. Part V Other Instruments for Avoiding Harmful Interference: New and alternative means for safeguarding the efficient use of spectrum resources for satellite communications, Simona Spassova; Harmful interference and human rights, Olga Batura. Part VI Outstanding Issues: The restructuring of an intergovernmental satellite communications organisation from a Luxmbourg perspective, Guy Modert.

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