Article

Comparative Contract Law

E. Allan Farnsworth

in The Oxford Handbook of Comparative Law

Published in print November 2006 | ISBN: 9780199296064
Published online September 2012 | | DOI: http://dx.doi.org/10.1093/oxfordhb/9780199296064.013.0029

Series: Oxford Handbooks in Law

Comparative Contract Law

Preview

This article presents an overview of comparative contract law. It reveals a number of differences between civilian legal systems and the common law, and also between French and German law as two main exponents of the civil-law tradition and, to some extent, even between English and US-American law. The same is true of other major issues in the field of general contract law that have not been touched upon. But there is a gradual convergence. This convergence is due to developments in all of the four legal systems covered in this article: English, US-American, French, and German law. And it has enabled scholars from around the world to elaborate an international restatement of contract law (the UNIDROIT Principles of International Commercial Contracts) and scholars from all the member states of the European Union to formulate a restatement of European contract law (the Principles of European Contract Law).

Keywords: civilian legal systems; general contract law; French law; German law; UNIDROIT

Article.  17909 words. 

Subjects: Law ; Comparative Law

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