LEGAL TRANSPLANTS OF TPF: FROM COMMON LAW TO CIVIL LAW

28.06.2024 "Modern Science and Research" xalqaro ilmiy jurnali 1 seriyasi. Volume 3 Issue 6

Abstract. Third-party funding (TPF) has emerged as a powerful tool in international arbitration, particularly in common law jurisdictions. This article explores the phenomenon of TPF as a legal transplant, examining its transfer from common law systems with established TPF practices to civil law jurisdictions that are grappling with its adoption and integration.

Keywords: Third-party funding (TPF), legal transplants, international arbitration, common law, civil law, access to justice, cultural attitudes.


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