Dr Gerooms has converted her thesis, originally submitted to the Catholic University of Leuven, into a monograph, now published by the Oxford University Press in its Private International Law Series. It is in very many respects an admirable addition though, in the opinion of this reviewer, also open to some serious scepticism.

Dr Gerooms looks at the role of foreign law in civil litigation. She looks at its relevance, at the manner in which it is to be ascertained, at the manner in which it is applied, and at the manner in which its application may be reviewed or corrected on appeal or cassation. She takes as her source material the laws of and legal writing from Belgium, England, France, Germany, the Netherlands and the United States. Her intention, and the result of pursuing it, was, as she tells us at the end, ‘‘to lay the foundations for the ideal procedural treatment of foreign law through a comparative study. On the basis of a few existing studies on the subject, the conviction gained ground that comparative research could reveal the best aspects of each system. As time passed and knowledge of the subject became more profound (however relative that might be), instead the notion grew slowly but firmly that an ideal procedural treatment of foreign law simply does not exist’’ (p 389).

In travelling this far, and in producing a remarkably well-documented account, Dr Gerooms has performed two most valuable services. First, she has set out, in accessible and (one presumes) accurate form, the approaches of the six legal systems under review. Anyone reading the book will be left with the firm impression that he or she now understands, at least, the general structure of the law on proof, application, and review, of foreign law in local litigation, and this from six countries; and will also be aware that there are more similarities between systems supposed to be different, and more divergences between those assumed to be the same. It is hard to over-state the advantage which this offers. Secondly, Dr Gerooms has established that comparative law can really do little more than simply observe that each system is different; that the rules are all coherent within the legal system in which they operate; and that it is unreal to suppose that any exercise in harmonization of approaches to proof of foreign law, whether made on the back of this survey or proposed by those in thrall to the dogma that homogenization is the meaning of legal life, makes sense. Whether Dr Gerooms is satisfied or dissatisfied with her conclusions is not completely clear. One may take the view that the diversity and disparity which she lays bare is the beneficial end product of a free market: that each system offers its own version of litigation service, and that those who wish to litigate may choose, that good law will drive out bad, and so forth. Or one may take the view that all this diversity now needs to be brought under control, and that the white heat of the intellectual technological revolution will accomplish it. Dr Gerooms hints that, in her opinion, tomorrow’s lawyers will be astonished at the difficulty which today’s lawyers seem to find in the application of foreign law: she points to globalization, the internet, CD-roms, and the general, if unsorted, mass of information about foreign law to which those who wish to may now have recourse: it is not hard, she considers, to find out what foreign law provides. Some may think that all this new availability

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