Ausländisches Recht im deutschen und englischen Zivilprozess

German civil courts will not be spared from continuing globalization. Nowadays, matters in dispute are not only affected by the laws in foreign countries, the number of disputes decided according to foreign law is also increasing. Thus the German judge is faced with the problem of how the French law of succession, the Turkish law pertaining to the legal consequences of divorce or the Japanese contractual law are to be applied correctly. Thomas Rogoz studies the demands made on the court and the aids available in order to deal with a problem which seems impossible to solve. In doing so, he makes a comparison with the law in England, where the application of foreign law is generally left up to the parties concerned. In conclusion, the author deals with the question of which approach is the best.