Zróżnicowanie poziomu i struktury zadłużenia gospodarstw domowych w krajach Unii Europejskiej

Abstract

The regulation 44/2001 on jurisdiction and recognition and enforcement of judgements in civil and commercial matters, known as Brussels I, creates the main fundament of current European civil procedural law. However, it is possible to observe that numerous changes and improvements have been suggested by certain authors during last years and that some of those ideas seem to touch the very essence of the whole act, namely the issue of the scope of general jurisdiction rules. The article presents the most important doubts and arguments raised in that debate, as well as the solutions suggested by the European Commission in the Green Paper from 2009 and in the recent official proposal of review from December 2010. The most crucial proposal provides the possibility of including defendants from countries outside EU into the scope of application of Brussels I. The question arises about the consequences of such step for the relations between different legal orders.