Die Privatscheidung im deutschen und gemeinschaftsrechtlichen Internationalen Privat- und Verfahrensrecht

Veronika Gärtner analyzes extra-judicial divorces in German private international law as well as Community law, in particular in view of recent developments at a European level. The analysis focuses on the fundamental tension between an increased appreciation of cultural diversity which is facing an enhanced regionalization and Europeanization. The author shows that a new approach by private international law - the so called principle of mutual recognition - is largely replacing traditional private international law. However, she argues that the premises of Community private international law are not necessarily suitable for situations having a strong link to third states and dealing with issues greatly influenced by cultural - and therefore also religious - questions.