Jump to Content Jump to Main Navigation

Part 1 Comparative Overview of Concepts of Attorney–Client Privilege, 6 Comparison—Similarities and Differences in the Laws on Attorney–Client Privilege

From: Attorney-Client Privilege in International Arbitration

Annabelle Möckesch

From: Oxford Legal Research Library (http://olrl.ouplaw.com). (c) Oxford University Press, 2015. All Rights Reserved.date: 30 October 2020

Privilege — Choice of law — Conflict of laws — Arbitrators — Conduct of proceedings — Confidentiality

This chapter compares the attorney–client privilege laws set out in the previous chapters. More specifically, it compares the following main features of the privilege: its purpose and rationale, its invocation, its scope (ratione personae, ratione materiae, and ratione temporis), exceptions to it, waiver of it, and work–product protection. It thereby identifies similarities and differences between the privilege laws in the reviewed jurisdictions and, in addition, examines the reasons for such differences.

Users without a subscription are not able to see the full content. Please, subscribe or login to access all content.