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Jurisdiction as between England, Scotland and Northern Ireland
For the purposes of Regulation 44/2001 and the Brussels and Lugano Convention the United Kingdom is one state. However, it is made up of three constituent legal parts—England and Wales, Scotland and Northern Ireland. Because these parts have different legal systems it is domestically necessary to provide a connecting factor between a dispute and a particular part if the jurisdictional factor provided by the regimes is a link with the United Kingdom as a whole, or conversely with a “place” in the United Kingdom. In addition the United Kingdom adapted the Brussels Convention structure to disputes having connections with two or more of the three parts. For proceedings started on or after 1 March 2002 the adaptation was amended so as with one exception to be based on the Regulation. Allocation of jurisdiction within the United Kingdom has therefore three functions:
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