The application of forum non conveniens varies across countries, with common law nations like the U.S., UK, and Canada using it to dismiss cases to more appropriate jurisdictions based on factors like witness convenience and local interest. However, the degree of flexibility differs, with U.S. courts often being more protective of the plaintiff’s chosen forum, while civil law countries like France and Germany focus more on jurisdictional competence. Global legal practices highlight the balance between efficiency and fairness, showing that while some jurisdictions prioritize judicial economy and efficiency, others emphasize protecting access to justice. Understanding these differences helps lawyers navigate international litigation, ensuring they consider both the practical and legal implications of filing in a particular forum.
