Abstract
LL.M. (International Commercial Law)
This dissertation concerns a comparative analysis of Brazilian, Indian and South
African private international law principles on the exercise of jurisdiction in
international civil and commercial cases. The intention is to uncover the fundamental
grounds of jurisdiction in these legal systems and in doing so draw attention to their
comparable characteristics. Emphasis is placed on matters of a commercial nature.
Furthermore, a discussion of the Hague Convention on Choice of Court Agreements
provides insight on the Convention’s purpose and its possible influence on and
implications for jurisdictional rules found in the private international law of the IBSA
countries should they become members to the Convention.