Private International Law in Commonwealth Africa

This book provides a comprehensive and comparative examination of private international law in Commonwealth Africa. It offers an unrivalled breadth of coverage in its examination of the law in Botswana, the Gambia, Ghana, Kenya, Lesotho, Malawi, Namibia, Nigeria, Sierra Leone, South Africa, Swaziland, Tanzania, Uganda, Zambia and Zimbabwe. The book is clearly and logically structured - it is organised around broad themes or issues, with country reports and accompanied by detailed commentaries. Drawing on nearly 1500 cases decided by courts in these countries and numerous national statutes, this book covers the four cornerstones of private international law: jurisdiction, choice of law, foreign judgements and arbitral awards enforcement, and international civil procedure. The author also provides an extensive bibliography of the literature on African private international law. Scholars and practitioners alike will find Private International Law in Commonwealth Africa invaluable and illuminating.

Introduction; Part I. Preliminary Matters: 1. Conceptual issues in choice of law; 2. Foreign law; 3. Domicile; Part II. Jurisdiction: 4. Bases of jurisdiction; 5. Forum non conveniens, lis alibi pendens and forum selection; 6. Limitations on jurisdiction; Part III. Obligations: 7. Contract; 8. Torts; 9. Foreign currency obligations; 10. Bills of exchange; Part IV. Family Law: 11. Marriage; 12. Bills of exchange; 13. Children; Part V. Property, Succession and Administration of Estates: 14. Property; 15. Succession; Part VI. Foreign Judgements and Arbitration Awards: 16. Administration of estates; 17. The common law regime for enforcing foreign judgements; 18. The statutory regimes for enforcing foreign judgements; 19. Recognition and enforcement of foreign arbitration awards; Part VII. International Civil Procedure: 20. Remedies in support of or against foreign judicial and arbitral proceedings; 21. International judicial assistance; 22. Security for costs.

Dr Richard Frimpong Oppong is an Assistant Professor in the Faculty of Law at Thompson Rivers University in Canada. He was the Director of Studies in Private International Law at The Hague Academy of International Law in 2012. He has published numerous articles and books and has been cited by the United States Court of Appeal for the Ninth Circuit and the South African Supreme Court of Appeal.