Volume III: Private International Law | Chapter 11 (1994): Public Policy
Completed October 1991, with a few more recent references.
52. The problem defined. – To give “concrete” expression to public policy, to adopt the terminology of Jayme,1 involves as stated previously (supra s. 4) a process in three broad stages: (1) the court must first consider the foreign law in question (supra s. 5 ss.), (2) then the circumstances of the case which disclose the relative nature of public policy (supra s. 24 ss.) and, finally, (3) it must relate the result to a legal system …