The Impact of French Tort Law on Mixed Jurisdictions: Quebec, Louisiana and Malta Compared

The Impact of French Tort Law on Mixed Jurisdictions: Quebec, Louisiana and Malta Compared
ISBN-10
3846515760
ISBN-13
9783846515761
Category
Torts
Pages
260
Language
English
Published
2011-10
Publisher
LAP Lambert Academic Publishing
Author
Diana Bajada

Description

This book takes as a point of departure the virtually ad verbatim reproduction of the Napoleonic tort general clause which existed in the mixed jurisdictions of Québec, Louisiana and Malta as common law infiltrated their area of tort law. The choice of countries provides the varying degrees which a mixed jurisdiction might display, concluding indeed that the impact left by French tort law has been absolute in Québec, largely rejected in Louisiana, with Malta located in an intermediate position of continuing interaction between civil and common law. --

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