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