Article

Comparative Tort Law

Gerhard Wagner

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/9780199296064.013.0032

Series: Oxford Handbooks in Law

 Comparative Tort Law

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Tort law has always been one of the major areas of comparative law. Whereas the law of property, even today, remains on the outskirts of comparative learning, the law of extra-contractual liability has attracted much interest from comparative law scholars. Endeavours in the comparison of the different systems of delict and tort have received a further boost from the objective of harmonizing European private law. This article consider general clauses versus a variety of individual torts, the scope of protection, the liability for fault, strict liability, and tort law and insurance. Regardless of whether one agrees or disagrees with the solutions offered, the principles and the commentaries thereon certainly provide a valuable starting-point for further scholarly efforts and critical discussion.

Keywords: comparative law; property law; individual tort; insurance; delict; European private law

Article.  19287 words. 

Subjects: Law ; Comparative Law

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