Duncan Fairgrieve

in State Liability in Tort

Published in print March 2003 | ISBN: 9780199258055
Published online March 2012 | e-ISBN: 9780191698507 | DOI:

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This chapter reviews the differences in the systems of substantive English and French governmental law in liability in terms of the approach, philosophy, and procedural factors, and similarities in the division between personal and state liability, concepts, approach, system of reparation, outcomes, and reasonable limitations of liability that make the two jurisdictions less divergent than they may at first seem. They also have parallels in the evolution of liability and the gradual liberalising of the substantive law. French law might learn from English law, as English law might learn from French law, to cope with the limitations of each system and to provide reference for progress and significant improvement.

Keywords: state liability; liability; governmental law; substantive law; French law; English law

Chapter.  11903 words. 

Subjects: Civil Law

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