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This paper discusses the extent to which the common law recognized public interest considerations when confronted with utility insolvencies in the UK, Australia, and the US in the period 1825 to 1970. Jurisprudence in all three jurisdictions concerning insolvent utilities arose in the nineteenth century out of the difficulties arising from the financial distress of railway companies. It is argued that public interest considerations were mobilized to justify various degrees of restriction on the usual rights of creditors in all jurisdictions. While evidence was found of the use of public interest theory in all jurisdictions, there was little development of it in the UK and Australia compared with the US. This may have been because of the early introduction of statutory schemes of arrangement in both countries and because of the nationalization of the industries for the better part of the twentieth century. In the US, on the other hand, public interest theory in the context of insolvent railways and other utilities was much more developed. In particular, it provided part of the rationale for the judicial development of the equity receivership into a comprehensive corporate reorganization mechanism. [ABSTRACT FROM AUTHOR]

This paper critically examines the law of forum non conveniens, in particular the use of the ‘clearly inappropriate forum’ test in Australia, compared with the ‘more appropriate forum’ test applied in jurisdictions such as the UK and the US. It traces the development of the law in the UK in relation to forum non conveniens, including the English acceptance of the doctrine, and how it has been applied in various cases. Some criticism of the ‘more appropriate forum’ test is noted, and it is not recommended that the courts adopt the ‘laundry list’ approach evident in some US decisions, where up to 25 different factors are considered in assessing a forum non conveniens application. It considers the Australian ‘clearly inappropriate forum’ test, and concludes that the ‘clearly inappropriate forum’ test should no longer be followed in that it is unnecessarily parochial and is not consistent with other goals of the rules of private international law including comity. Links between Australia and the subject matter may well be tenuous. Confusion attends the application of the test in Australia at present, the court has rejected the English approach but claims to apply some of the factors mentioned in the English approach in the Australian test, and there is an undesirable schism between statutory rules applicable in domestic cases and the approach when the common law doctrine of forum non conveniens is used. The law regarding forum non conveniens should be harmonious with choice of law rules, and interest analysis can assist in formulating the desired approach to forum non conveniens applications. [ABSTRACT FROM AUTHOR]

The article cites a study that analyses if changes introduced in Great Britain's law have more stringent anti-money laundering measures at some offshore financial centers as compared to their onshore counterparts. It is noted that the study focused on the Crown Dependencies and the British Overseas Territories of Bermuda and the Cayman Islands. The study included the U.S., Great Britain and Australia as the onshore jurisdiction. According to the study, the Crown Dependencies and the selected Overseas Territories are outdoing the onshore jurisdiction in many cases.

Purpose: The objective of this review is to report on recent developments in youth mental health incorporating all levels of severity of mental disorders encouraged by progress in the field of early intervention in psychotic disorders, research in deficiencies in the current system and social advocacy.Methods: The authors have briefly reviewed the relevant current state of knowledge, challenges and the service and research response across four countries (Australia, Ireland, the UK and Canada) currently active in the youth mental health field.Results: Here we present information on response to principal challenges associated with improving youth mental services in each country. Australia has developed a model comprised of a distinct front-line youth mental health service (Headspace) to be implemented across the country and initially stimulated by success in early intervention in psychosis; in Ireland, Headstrong has been driven primarily through advocacy and philanthropy resulting in front-line services (Jigsaw) which are being implemented across different jurisdictions; in the UK, a limited regional response has addressed mostly problems with transition from child-adolescent to adult mental health services; and in Canada, a national multi-site research initiative involving transformation of youth mental health services has been launched with public and philanthropic funding, with the expectation that results of this study will inform implementation of a transformed model of service across the country including indigenous peoples.Conclusions: There is evidence that several countries are now engaged in transformation of youth mental health services and in evaluation of these initiatives. [ABSTRACT FROM AUTHOR]

The article discusses the developments in jurisdictions of Australia, Great Britain and the U.S where litigation financing has established a beachhead. Topics discussed include a niche position occupied by litigation funding in the subprime consumer lending market in the U.S, how professional conduct rules and regulation in jurisdictions of these countries hinder the development of markets in litigation risk, and transfer of litigation risk from both the claim holder and the claim respondent.

The search for simplicity in legislative drafting affects all legislatures. It is also central to the work of the New Zealand Law Commission and of governments in other comparable jurisdictions. Rather than exploring a range of statutes in various jurisdictions, this article focuses on income tax. It does so for two reasons. The first is that income tax has been crucial to the funding of government in common law jurisdictions and to achieving a legislative balance between simplicity and other criteria of an acceptable tax system. The second is that we can draw on three recent projects to rewrite income tax legislation - in Australia, the United Kingdom and New Zealand. [ABSTRACT FROM AUTHOR]

Construction contract law in the common law world is largely free of direct statutory intervention. The agenda of calls within the United Kingdom to remedy major defects in construction law is used as a framework in a series of comparisons with recent legislation and practice in Australia, notably in Victoria where a holistic approach to the industry's problems has been adopted with signal success. It is suggested that policy makers in the UK consider what Commonwealth jurisdictions have to offer to the solution of homegrown problems. [ABSTRACT FROM AUTHOR]