What are the four grounds for excluding foreign law?
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ChatGPT
May 4
1. Public policy: If the application of foreign law would violate the fundamental principles of justice or public policy in the forum state, it may be excluded.
2. Contrary to the forum's legal system: If the application of foreign law would conflict with the fundamental principles or rules of the forum state's legal system, it may be excluded.
3. Lack of connection: If there is no substantial connection between the legal issue at hand and the foreign law in question, the foreign law may be excluded.
4. Incompatibility with forum's legal system: If the foreign law is fundamentally incompatible with the legal principles or values of the forum state, it may be excluded.
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Google Gemini AI
May 4
1. Violation of public order 2. Lack of reciprocity 3. Notice, only if its omission was prejudicial 4. Lack of a remedy