Lex loci celebrationis - Ein neues Anknüpfungsprinzip für die internationale Eheschließung

This book examines the need for reform of private international law relating to marriage in the context of an increasingly mobile and diverse society. Taking as its starting point the conflict-of-laws distinction between different-sex and same-sex marriages under the current German autonomous private international law rules, it analyses various reform proposals. Particular attention is given to the proposal of uniformly applying the lex loci celebrationis, that is, the law of the place where the marriage is celebrated. The book demonstrates that this approach offers a coherent and forward-looking framework for the modernization of private international law of marriage.