Abstract
Abstract This chapter compares the attorney–client privilege laws set out in the previous chapters. More specifically, it compares the following main features of the privilege: its purpose and rationale, its invocation, its scope (ratione personae, ratione materiae, and ratione temporis), exceptions to it, waiver of it, and work–product protection. It thereby identifies similarities and differences between the privilege laws in the reviewed jurisdictions and, in addition, examines the reasons for such differences.
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