The Recognition of Foreign Law: Foreign Maritime Liens under Mexican Law

• Autores: Abraham Alejandro Servín Caamaño
• Localización: Mexican Law Review, ISSN 1870-0578, ISSN-e 2448-5306, Vol. 10, Nº. 1, 2017, págs. 45-67
• Idioma: inglés
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• Resumen

  • Maritime liens, without a doubt, are a unique and hugely important feature of maritime law. Broadly speaking, they represent a claim on or special right to a vessel. However, there is no uniformity when it comes to studying this unique feature. It is from the Anglo-Saxon jurisdictions that we get the majority of our information about its nature and associated problems. In this article, the law on maritime liens is examined through a comparative study of several Anglo-Saxon jurisdictions and Mexican law. Also under investigation are the problems that arise when a national court is faced with a maritime lien created under foreign law, and when that maritime lien differs from those liens established under the law that governs the domestic court.