Mistake and Non-Disclosure in Other Systems

Hugh Beale

in Mistake and Non-Disclosure of Facts

Published in print August 2012 | ISBN: 9780199593880
Published online September 2012 | e-ISBN: 9780191745362 | DOI:

Series: Clarendon Law Lectures

Mistake and Non-Disclosure in Other Systems

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This chapter examines a selection of other laws of contract, particularly models found in national systems that supposedly form the basis of the PECL provisions. It first studies the Commonwealth laws, where it identifies two cases that have deviated from the doctrine of unconscionability. The next section deals with European models, specifically Dutch, French, Scandinavian, and German laws. The laws of individual states in the U.S. are discussed in the final part of the chapter.

Keywords: laws of contract; national systems; PECL provisions; commonwealth laws; doctrine of unconscionability; European models; laws of individual states

Chapter.  15827 words. 

Subjects: Civil Law

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