How English Courts Approach Comity When Laws Conflict

By Nick Barnard (January 14, 2020, 5:18 PM EST) -- The principle of comity holds that, as a starting point, the law of one jurisdiction should seek to recognize the law of another and, where necessary, promote and protect the other legal system's interests.

This is all very well where the intersecting laws complement, or at least do not contradict, each other. But what weight does the principle carry when the laws of two jurisdictions are in conflict? In particular, what should a court do when the law of one jurisdiction exposes a person to criminal prosecution in respect of conduct that the law of the other jurisdiction obliges a person...

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