Bringing together leading commercial and contract law scholars from the United Kingdom and United States, Comparative Contract Law: British and American Perspectives offers an insightful and comprehensive assessment of the commonalities and divergences in the contract law of these twojurisdictions. Approaching the subject area from a variety of perspectives - doctrinal analysis, behavioural analysis, law and economics, and theoretical - the book examines familiar areas of contract law as practiced in the UK and US. Topics include contract theory and structure; contract formationand defects of consent; policing contracts and the duty of good faith; contract interpretation; damages; speciality contracts; and legal reform. The volume provides a thorough assessment of the current state of commercial contract law in the UK and US, and addresses the strengths and weaknesses of the national and European approaches to many issues of contract law. In particular it focuses on how commercial contract law should be improved,and whether harmonization of the different contract law regimes is a suitable, and appropriate, solution.
Craswell, R. (1989) 'Contract Law, Default Rules, and the Philosophy of Promising' 88 Michigan Law Review 489 Dagan, ... Oxford: Oxford University Press, 3rd edn Kelsen, H. (1997) Introductions to the Problems of Legal Theory (Bonnie ...
27), at p. 371: “Courts are playing an impressive role in the creation of what some see as a 'common law of human rights' or, in the context of Europe, 'a ius commune of human rights'”; McCrudden (fn.4), at pp. 499 ff.; A.-M. Slaughter, ...
This revised second edition has been updated to reflect the most recent changes in the law, including the French reform of the law of obligations and the new UK Consumer Rights Act.
Reflecting the most recent changes in the law, the third edition of this popular textbook provides a fully updated, comparative introduction to the law of contract.
This well-documented book will appeal to postgraduate students and scholars of law and economics, and comparative law. Judges and law practitioners will also find much to interest them in this pioneering volume. Contents: 1. Introduction 2.
We are, of course, all Europeans now. However, what strikes people who do business across the EU is the radical differences between legal systems and philosophies. It is dangerous to...
This book provides a comparative study of contract law, examining the interaction of common law and civil law approaches to contract law.
Comparative Contract Law and Economics provides a deeper understanding of the similarities and differences between the legal systems of France, England, the US and Germany in terms of contract law.
Together with an original introduction by the editor this compilation of classic key papers by leading scholars endeavours to facilitate such appreciation and will prove an essential reference point for students, researchers and ...
This is a casebook with an emphasis on Continental law, in a comparative, American-style format, with many references to U.S. and U.K. law.