Pub Date : 2023-12-06DOI: 10.1177/1023263x231216941
Shu Li, Béatrice Schütte
On September 28, 2022, the European Commission presented the long-awaited proposal for a revised Product Liability Directive (PLD). By adapting rules and concepts to digitalization and circular economy, the revised PLD aims to ensure that the damage that defective products caused can be remedied adequately. This paper provides a comprehensive analysis of the substantive and procedural harmonized rules that are reshaped in the revised PLD. The discussion shows that although the revised version makes progress, ambiguities remain about essential concepts such as ‘product’, ‘damage’, and ‘defectiveness’. Those ambiguities could generate significant legal uncertainties. In addition, it is imperative to consider whether the harmonization that results from the revised PLD strikes a balance between centralized policy goals and local preferences. Since it has been reiterated that the revised PLD will be limited to safety-related harm rather than to harm to other fundamental rights (e.g., data protection and equal treatment), it is also crucial to inquire whether harms of the latter kind can be remedied effectively by other relevant legal regimes.
{"title":"The proposal for a revised Product Liability Directive: The emperor's new clothes?","authors":"Shu Li, Béatrice Schütte","doi":"10.1177/1023263x231216941","DOIUrl":"https://doi.org/10.1177/1023263x231216941","url":null,"abstract":"On September 28, 2022, the European Commission presented the long-awaited proposal for a revised Product Liability Directive (PLD). By adapting rules and concepts to digitalization and circular economy, the revised PLD aims to ensure that the damage that defective products caused can be remedied adequately. This paper provides a comprehensive analysis of the substantive and procedural harmonized rules that are reshaped in the revised PLD. The discussion shows that although the revised version makes progress, ambiguities remain about essential concepts such as ‘product’, ‘damage’, and ‘defectiveness’. Those ambiguities could generate significant legal uncertainties. In addition, it is imperative to consider whether the harmonization that results from the revised PLD strikes a balance between centralized policy goals and local preferences. Since it has been reiterated that the revised PLD will be limited to safety-related harm rather than to harm to other fundamental rights (e.g., data protection and equal treatment), it is also crucial to inquire whether harms of the latter kind can be remedied effectively by other relevant legal regimes.","PeriodicalId":39672,"journal":{"name":"Maastricht Journal of European and Comparative Law","volume":"64 8","pages":""},"PeriodicalIF":0.0,"publicationDate":"2023-12-06","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"138596439","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Pub Date : 2023-11-27DOI: 10.1177/1023263x231213335
Laura Treviño-Lozano, Ezgi Uysal
The link between human rights and environmental due diligence and public procurement has been recognized in soft law, and in a less consistent way in EU hard law. Particularly, it has been an issue of concern in the law-making process for the EU Corporate Sustainability Due Diligence Directive. Despite increasing attention, considerable debate remains over the inclusion of human rights and environmental due diligence in public procurement, which is still an underdeveloped topic. This article contributes to enlightening the debate and filling this gap by exploring the link between human rights and environmental due diligence and public procurement, then by analysing whether and how human rights and environmental due diligence can be incorporated into EU public procurement as a contract performance condition and comply with the requirement of the link to the subject matter of the contract.
{"title":"Bridging the gap between corporate sustainability due diligence and EU public procurement","authors":"Laura Treviño-Lozano, Ezgi Uysal","doi":"10.1177/1023263x231213335","DOIUrl":"https://doi.org/10.1177/1023263x231213335","url":null,"abstract":"The link between human rights and environmental due diligence and public procurement has been recognized in soft law, and in a less consistent way in EU hard law. Particularly, it has been an issue of concern in the law-making process for the EU Corporate Sustainability Due Diligence Directive. Despite increasing attention, considerable debate remains over the inclusion of human rights and environmental due diligence in public procurement, which is still an underdeveloped topic. This article contributes to enlightening the debate and filling this gap by exploring the link between human rights and environmental due diligence and public procurement, then by analysing whether and how human rights and environmental due diligence can be incorporated into EU public procurement as a contract performance condition and comply with the requirement of the link to the subject matter of the contract.","PeriodicalId":39672,"journal":{"name":"Maastricht Journal of European and Comparative Law","volume":"37 1","pages":""},"PeriodicalIF":0.0,"publicationDate":"2023-11-27","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"139234196","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Pub Date : 2023-10-25DOI: 10.1177/1023263x231206007
Päivi Hutukka
This study presents the main features of patent law in the European Union, the United States and China, with a special focus on patentability. Each patent regime is reviewed in its historical context, exploring the stages leading to the given jurisdiction's contemporary patent law. After mapping the differences and similarities of patent law in the EU, the US and China, possible reasons for the detected divergence and convergence will be explored. This study reveals that the differences in codified patent law between the EU, the US, and China are for the most part a matter of nuance and much of the convergence stems from international harmonization efforts and common historical roots as well as external pressure to convergence in patent law for mainly economic reasons. Whereas patent laws in the EU and US are more established, China's patent law has been moulded into its contemporary form only recently. Differences across the chosen jurisdictions are explained not only by cultural factors but also by underlying theoretical differences in patent doctrine and differing aims of patent protection, as well as the divide concerning the role of statutory law and case law between the common law and Romano-Germanic law.
{"title":"Patent law in comparative context: Differences and similarities of patent law in he European Union, the United States and China","authors":"Päivi Hutukka","doi":"10.1177/1023263x231206007","DOIUrl":"https://doi.org/10.1177/1023263x231206007","url":null,"abstract":"This study presents the main features of patent law in the European Union, the United States and China, with a special focus on patentability. Each patent regime is reviewed in its historical context, exploring the stages leading to the given jurisdiction's contemporary patent law. After mapping the differences and similarities of patent law in the EU, the US and China, possible reasons for the detected divergence and convergence will be explored. This study reveals that the differences in codified patent law between the EU, the US, and China are for the most part a matter of nuance and much of the convergence stems from international harmonization efforts and common historical roots as well as external pressure to convergence in patent law for mainly economic reasons. Whereas patent laws in the EU and US are more established, China's patent law has been moulded into its contemporary form only recently. Differences across the chosen jurisdictions are explained not only by cultural factors but also by underlying theoretical differences in patent doctrine and differing aims of patent protection, as well as the divide concerning the role of statutory law and case law between the common law and Romano-Germanic law.","PeriodicalId":39672,"journal":{"name":"Maastricht Journal of European and Comparative Law","volume":"61 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2023-10-25","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"135168561","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Pub Date : 2023-10-25DOI: 10.1177/1023263x231208835
Shu Li
The Court of Justice of the European Union delivered a decision in Case C-300/21 to address three questions on how to compensate a data subject for the non-material damage suffered from a violation of GDPR provisions. First, infringement by itself does not give rise to compensation. Actual damage must be demonstrated by the data subject. Second, the right to compensation is not limited to non-material damage that reaches a certain threshold of seriousness. Third, since the GDPR does not provide an explicit guideline for assessing damages, it falls to Member States to establish such a criterion. The criterion, nevertheless, must comply with the principle of equivalence and effectiveness. The judgment, together with the Advocate General's opinion, touches upon several fundamental issues at the intersection of risk, harm and tort damage.
{"title":"Compensation for non-material damage under Article 82 GDPR: A review of Case C-300/21","authors":"Shu Li","doi":"10.1177/1023263x231208835","DOIUrl":"https://doi.org/10.1177/1023263x231208835","url":null,"abstract":"The Court of Justice of the European Union delivered a decision in Case C-300/21 to address three questions on how to compensate a data subject for the non-material damage suffered from a violation of GDPR provisions. First, infringement by itself does not give rise to compensation. Actual damage must be demonstrated by the data subject. Second, the right to compensation is not limited to non-material damage that reaches a certain threshold of seriousness. Third, since the GDPR does not provide an explicit guideline for assessing damages, it falls to Member States to establish such a criterion. The criterion, nevertheless, must comply with the principle of equivalence and effectiveness. The judgment, together with the Advocate General's opinion, touches upon several fundamental issues at the intersection of risk, harm and tort damage.","PeriodicalId":39672,"journal":{"name":"Maastricht Journal of European and Comparative Law","volume":"4 2","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2023-10-25","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"135166072","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Pub Date : 2023-10-23DOI: 10.1177/1023263x231205826
Cecilia Rizcallah
The principle of mutual trust has become a structural principle of EU law that underpins many rules of primary law as well as secondary legislation both in the field of internal market and in that of the area, of freedom, security and justice. Several questions in relation to this principle have had to be settled by the Court of Justice, particularly, with regard to the risks that it can pose for the protection of, fundamental rights in the area of freedom, security and justice. In this regard, the Court of Justice adopted a ‘stone-by-stone approach’, by progressively specifying the limits framing the principle of mutual trust on the basis of the specific cases it had to handle. Building on recent the case law, this paper offers a critical, examination of the balance struck by the Court of Justice between the, principle of mutual trust and the protection of fundamental rights.
{"title":"The principle of mutual trust and the protection of fundamental rights in the Area of Freedom, Security and Justice: A critical look at the Court of Justice's stone-by-stone approach","authors":"Cecilia Rizcallah","doi":"10.1177/1023263x231205826","DOIUrl":"https://doi.org/10.1177/1023263x231205826","url":null,"abstract":"The principle of mutual trust has become a structural principle of EU law that underpins many rules of primary law as well as secondary legislation both in the field of internal market and in that of the area, of freedom, security and justice. Several questions in relation to this principle have had to be settled by the Court of Justice, particularly, with regard to the risks that it can pose for the protection of, fundamental rights in the area of freedom, security and justice. In this regard, the Court of Justice adopted a ‘stone-by-stone approach’, by progressively specifying the limits framing the principle of mutual trust on the basis of the specific cases it had to handle. Building on recent the case law, this paper offers a critical, examination of the balance struck by the Court of Justice between the, principle of mutual trust and the protection of fundamental rights.","PeriodicalId":39672,"journal":{"name":"Maastricht Journal of European and Comparative Law","volume":"22 7","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2023-10-23","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"135412750","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Pub Date : 2023-10-12DOI: 10.1177/1023263x231205829
Lorenzo Bernardini, Gaetano Ancona
The recent decision of the Court of Justice of the European Union in HYA and Others has a significant impact on the use of untested witness statements in criminal proceedings. The case concerned the right to examine witnesses, which is protected under 6(3)(d) of the European Convention on Human Rights. The CJEU established a three-step test to determine whether the use of untested evidence violates the right to a fair trial and ruled out the use of ‘sole or decisive’ untested evidence in criminal proceedings. The Court also held that the right to examine witnesses is a fundamental right in criminal proceedings and falls within the scope of Article 8(1) of Directive 2016/343. The HYA and Others judgment sets a higher standard than that guaranteed by the ECtHR, preventing the use of sole or decisive witnesses in reaching a final conviction decision. Finally, the judgment extends the scope of defence rights in EU law and enhances the effectiveness of fundamental rights in criminal proceedings.
{"title":"<i>HYA and Others</i>: Reshaping participation at criminal trials in Europe","authors":"Lorenzo Bernardini, Gaetano Ancona","doi":"10.1177/1023263x231205829","DOIUrl":"https://doi.org/10.1177/1023263x231205829","url":null,"abstract":"The recent decision of the Court of Justice of the European Union in HYA and Others has a significant impact on the use of untested witness statements in criminal proceedings. The case concerned the right to examine witnesses, which is protected under 6(3)(d) of the European Convention on Human Rights. The CJEU established a three-step test to determine whether the use of untested evidence violates the right to a fair trial and ruled out the use of ‘sole or decisive’ untested evidence in criminal proceedings. The Court also held that the right to examine witnesses is a fundamental right in criminal proceedings and falls within the scope of Article 8(1) of Directive 2016/343. The HYA and Others judgment sets a higher standard than that guaranteed by the ECtHR, preventing the use of sole or decisive witnesses in reaching a final conviction decision. Finally, the judgment extends the scope of defence rights in EU law and enhances the effectiveness of fundamental rights in criminal proceedings.","PeriodicalId":39672,"journal":{"name":"Maastricht Journal of European and Comparative Law","volume":"42 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2023-10-12","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"136014420","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Pub Date : 2023-10-09DOI: 10.1177/1023263x231205830
Brigitte Steinbauer
Diversity and gender equality in executive boards, as well as finding ways to balance private needs and business requirements, are topics that are on the agenda of legislators around the globe. Given the significant role of executive board members in shaping organizational strategy and culture and for the company’s success, understanding the impact of rules that allow a mandate pause for this group is essential. The German ‘stay-on-board’ rules grant a mandate pause to board members for maternity, parental or care leave or for a board member's convalescence since August 2021. The objective of this paper is to examine the necessity for a legal framework on the European Union level that provides for a mandate pause for board members as a way to increase gender equality on the board level. The author recommends closing the gap in gender equality on the board level at European level by adopting comparable measures to those implemented in Germany, supplemented by additional measures. The implementation of a comprehensive set of measures, in conjunction with widespread acceptance in society, is crucial for the advancement of gender equality within corporate boardrooms.
{"title":"Increasing gender equality on board level through stay-on-board regulations","authors":"Brigitte Steinbauer","doi":"10.1177/1023263x231205830","DOIUrl":"https://doi.org/10.1177/1023263x231205830","url":null,"abstract":"Diversity and gender equality in executive boards, as well as finding ways to balance private needs and business requirements, are topics that are on the agenda of legislators around the globe. Given the significant role of executive board members in shaping organizational strategy and culture and for the company’s success, understanding the impact of rules that allow a mandate pause for this group is essential. The German ‘stay-on-board’ rules grant a mandate pause to board members for maternity, parental or care leave or for a board member's convalescence since August 2021. The objective of this paper is to examine the necessity for a legal framework on the European Union level that provides for a mandate pause for board members as a way to increase gender equality on the board level. The author recommends closing the gap in gender equality on the board level at European level by adopting comparable measures to those implemented in Germany, supplemented by additional measures. The implementation of a comprehensive set of measures, in conjunction with widespread acceptance in society, is crucial for the advancement of gender equality within corporate boardrooms.","PeriodicalId":39672,"journal":{"name":"Maastricht Journal of European and Comparative Law","volume":"19 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2023-10-09","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"135146639","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Pub Date : 2023-10-09DOI: 10.1177/1023263x231205836
Inge Graef
Competition authorities can identify a violation of the data protection rules when such a finding is necessary to establish an abuse of dominance under the competition rules. This is the main outcome of the judgment that the Court of Justice of the European Union (CJEU) delivered in Meta Platforms on 4 July 2023. The judgment is the next step in the saga that started with the 2019 competition decision of the Bundeskartellamt (the German Federal Cartel Office) requiring Facebook (now Meta) to refrain from combining user data from different sources beyond its social network. The judgment provides a welcome confirmation that data protection standards can also matter for the interpretation of the competition rules. However, what is more remarkable and less expected is the general framework the CJEU sets out for coordination between competition and data protection authorities building on the duty of sincere cooperation and the clarity with which it evaluates the different legal bases Meta invoked for processing user data. The judgment can become a reference point for assessing the legality of personal data processing by powerful firms, but also leaves competition and data protection authorities with an assignment to explore how to coordinate their work in the future.
{"title":"<i>Meta platforms</i>: How the CJEU leaves competition and data protection authorities with an assignment","authors":"Inge Graef","doi":"10.1177/1023263x231205836","DOIUrl":"https://doi.org/10.1177/1023263x231205836","url":null,"abstract":"Competition authorities can identify a violation of the data protection rules when such a finding is necessary to establish an abuse of dominance under the competition rules. This is the main outcome of the judgment that the Court of Justice of the European Union (CJEU) delivered in Meta Platforms on 4 July 2023. The judgment is the next step in the saga that started with the 2019 competition decision of the Bundeskartellamt (the German Federal Cartel Office) requiring Facebook (now Meta) to refrain from combining user data from different sources beyond its social network. The judgment provides a welcome confirmation that data protection standards can also matter for the interpretation of the competition rules. However, what is more remarkable and less expected is the general framework the CJEU sets out for coordination between competition and data protection authorities building on the duty of sincere cooperation and the clarity with which it evaluates the different legal bases Meta invoked for processing user data. The judgment can become a reference point for assessing the legality of personal data processing by powerful firms, but also leaves competition and data protection authorities with an assignment to explore how to coordinate their work in the future.","PeriodicalId":39672,"journal":{"name":"Maastricht Journal of European and Comparative Law","volume":"59 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2023-10-09","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"135146747","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Pub Date : 2023-10-09DOI: 10.1177/1023263x231202481
Ottavio Quirico
Multiple developments are taking place in the European Union (EU) as concerns climate action through fundamental rights. On the one hand, the Court of Justice of the European Union (CJEU) might afford protection from climate change via first- and second-generation human rights; on the other, the EU is progressively recognizing the human right to a sustainable environment, and possibly to a sustainable climate, via Article 37 of the Charter of Fundamental Rights. These developments are nonetheless restrained by the limited possibility for individual natural and legal persons to act in the Court. On the other hand, EU Member States are parties to the European Convention on Human Rights (ECHR), to which the EU will also foreseeably accede in the future and through which a string of claims has been brought to the attention of the European Court of Human Rights (ECtHR). Also in this context, protection from climate change might be afforded via first- and second-generation fundamental rights, and possibly via the third-generation right to a sustainable environment and climate. Contrary to the CJEU system, however, there are no procedural limits to action by individual natural and legal persons in the ECtHR. The article argues that an extensive interpretation of first- and second-generation human rights, particularly the rights to life and to private and family life under ECHR articles 2 and 8, collectively interpreted as the rights to live in a sustainable environment and climate in line with the jurisprudence of the ECtHR, reverses the burden of proof and is essentially tantamount to acknowledging an independent fundamental right to a sustainable environment and climate, thus ensuring adequate climate protection in the EU from a human rights perspective.
{"title":"The European Union and global warming: A fundamental right to (live in) a sustainable climate?","authors":"Ottavio Quirico","doi":"10.1177/1023263x231202481","DOIUrl":"https://doi.org/10.1177/1023263x231202481","url":null,"abstract":"Multiple developments are taking place in the European Union (EU) as concerns climate action through fundamental rights. On the one hand, the Court of Justice of the European Union (CJEU) might afford protection from climate change via first- and second-generation human rights; on the other, the EU is progressively recognizing the human right to a sustainable environment, and possibly to a sustainable climate, via Article 37 of the Charter of Fundamental Rights. These developments are nonetheless restrained by the limited possibility for individual natural and legal persons to act in the Court. On the other hand, EU Member States are parties to the European Convention on Human Rights (ECHR), to which the EU will also foreseeably accede in the future and through which a string of claims has been brought to the attention of the European Court of Human Rights (ECtHR). Also in this context, protection from climate change might be afforded via first- and second-generation fundamental rights, and possibly via the third-generation right to a sustainable environment and climate. Contrary to the CJEU system, however, there are no procedural limits to action by individual natural and legal persons in the ECtHR. The article argues that an extensive interpretation of first- and second-generation human rights, particularly the rights to life and to private and family life under ECHR articles 2 and 8, collectively interpreted as the rights to live in a sustainable environment and climate in line with the jurisprudence of the ECtHR, reverses the burden of proof and is essentially tantamount to acknowledging an independent fundamental right to a sustainable environment and climate, thus ensuring adequate climate protection in the EU from a human rights perspective.","PeriodicalId":39672,"journal":{"name":"Maastricht Journal of European and Comparative Law","volume":"25 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2023-10-09","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"135095279","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
{"title":"Purely Intramuscular Giant Epidermoid Cyst of the Temporalis Muscle.","authors":"Dimble Raju, Shamshuddin Patel, Sayan Das, Prasad Krishnan","doi":"10.1055/s-0043-1772766","DOIUrl":"10.1055/s-0043-1772766","url":null,"abstract":"","PeriodicalId":39672,"journal":{"name":"Maastricht Journal of European and Comparative Law","volume":"16 1","pages":"690-691"},"PeriodicalIF":0.0,"publicationDate":"2023-08-31","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"https://www.ncbi.nlm.nih.gov/pmc/articles/PMC10777719/pdf/","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"87694351","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"OA","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
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