Author: Zvonimir Slakoper
Publisher:
ISBN: 9781032063331
Category : Conflict of laws
Languages : en
Pages :
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Book Description
"EU Private Law and the CISG examines selected EU directives in the field of private law and their effects on the national private law systems of several EU Member States and discusses certain specific concepts of the United Nations Convention on Contracts for the International Sale of Goods (CISG) in light of the CISG's recent fortieth anniversary"--
Author: Study Group on a European Civil Code
Publisher: sellier. european law publ.
ISBN: 3866530595
Category : Civil law
Languages : en
Pages : 406
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Book Description
In this volume, the Study Group and the Acquis Group present the first academic Draft of a Common Frame of Reference (DCFR). The Draft is based in part on a revised version of the Principles of European Contract Law (PECL) and contains Principles, Definitions and Model Rules of European Private Law in an interim outline edition. It covers the books on contracts and other juridical acts, obligations and corresponding rights, certain specific contracts, and non-contractual obligations. One purpose of the text is to provide material for a possible "political" Common Frame of Reference (CFR) which was called for by the European Commission's Action Plan on a More Coherent European Contract Law of January 2003.
Author: Joseph M. Lookofsky
Publisher:
ISBN:
Category : Aftaleret
Languages : en
Pages : 222
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Book Description
Author: Ingeborg Schwenzer
Publisher: Oxford University Press, USA
ISBN: 0199572984
Category : Business & Economics
Languages : en
Pages : 1069
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Book Description
This comprehensive analysis of domestic and international sales law covering over sixty jurisdictions is the most detailed work in the field. It includes all aspects of a sale of goods transaction and provides answers to complex issues in practice.
Author: María Campo Comba
Publisher: Springer Nature
ISBN: 3030614816
Category : Law
Languages : en
Pages : 380
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Book Description
This book provides answers to the following questions: how do traditional principles of private international law relate to the requirements of the internal market for the realisation of the EU’s objectives regarding the protection of weaker parties such as consumers and employees? When and how should private international law ensure the applicability of EU directives concerning the protection of weaker parties? Are the EU’s current private international law, rules on conflict of laws, and private international law approach sufficient to ensure the realisation of its objectives regarding weaker contracting parties, or is a different approach to private international law called for? The book concludes with several proposed amendments, mainly regarding the Rome I Regulation on the law applicable to contractual obligations, as well as suggestions on the EU’s current approach to private international law. This book is primarily intended for an academic audience and to help achieve better regulation in the future. It also seeks to dispel certain lingering doubts regarding the current practice of EU private international law.
Author: Commission on European Contract Law
Publisher: Kluwer Law International B.V.
ISBN: 9041113053
Category : Law
Languages : en
Pages : 612
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Book Description
This text provides a comprehensive guide to the principles of European contract law. They have been drawn up by an independent body of experts from each Member State of the EU, under a project supported by the European Commission and many other organizations. The principles are stated in the form of articles, with a detailed commentary explaining the purpose and operation of each article and its relation to the remainder. Each article also has extensive comparative notes surveying the national laws and other international provisions on the topic.
Author: Nils Jansen
Publisher: Oxford University Press
ISBN: 0192508016
Category : Law
Languages : en
Pages : 3650
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Book Description
The book provides rule-by-rule commentaries on European contract law (general contract law, consumer contract law, the law of sale and related services), dealing with its modern manifestations as well as its historical and comparative foundations. After the collapse of the European Commission's plans to codify European contract law it is timely to reflect on what has been achieved over the past three to four decades, and for an assessment of the current situation. In particular, the production of a bewildering number of reference texts has contributed to a complex picture of European contract laws rather than a European contract law. The present book adopts a broad perspective and an integrative approach. All relevant reference texts (from the CISG to the Draft Common European Sales Law) are critically examined and compared with each other. As far as the acquis commun (ie the traditional private law as laid down in the national codifications) is concerned, the Principles of European Contract Law have been chosen as a point of departure. The rules contained in that document have, however, been complemented with some chapters, sections, and individual provisions drawn from other sources, primarily in order to account for the quickly growing acquis communautaire in the field of consumer contract law. In addition, the book ties the discussion concerning the reference texts back to the pertinent historical and comparative background; and it thus investigates whether, and to what extent, these texts can be taken to be genuinely European in nature, ie to constitute a manifestation of a common core of European contract law. Where this is not the case, the question is asked whether, and for what reasons, they should be seen as points of departure for the further development of European contract law.
Author: Christian Twigg-Flesner
Publisher: Cambridge University Press
ISBN: 1107493978
Category : Law
Languages : en
Pages : 381
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Book Description
The emergence of EU Private Law as an independent legal discipline is one of the most significant developments in European legal scholarship in recent times. In this 2010 Companion, leading scholars provide a critical introduction to the subject's key areas, while offering original and thought-provoking comment on the field. In addition to several chapters on consumer law topics, the collection has individual chapters on commercial contracts, competition law, non-discrimination law, financial services and travel law. It also discusses the wider issues concerning EU Private Law, such as its historical evolution, the role of comparative law, language and terminology, as well as the implications of the Common Frame of Reference project. A useful 'scene-setting' introduction and further reading arranged thematically make this important publication the student's and scholar's first port of call when exploring the field.
Author: Franco Ferrari
Publisher: Walter de Gruyter
ISBN: 3866537298
Category : Law
Languages : en
Pages : 500
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Book Description
In force in 70 countries around the world and covering more than two thirds of world trade, the 1980 United Nations Convention on Contracts for the International Sale of Goods (CISG) is considered to be the most successful convention promoting international trade. According to many commentators, this success is due, among others, to the fact that the Convention does not directly impact on the domestic law of the various legal systems, as it applies only to international - as opposed to purely domestic - contracts. The Convention, in other words, does not impose changes in the domestic law, which makes it easier for States to adopt the Convention. This does not mean, however, that the Convention does not have any impact on the domestic law at all. This book analyzes - through 24 country reports as well as a general report submitted to the 1st Intermediate Congress of the International Academy of Comparative Law held in November 2008 in Mexico City - to what extent the Convention de facto influences domestic legal systems. In particular, the book examines the Convention's impact on the practice of law, the style of court decisions as well as the domestic legislation in the area of contract law.
Author: Stefan Kröll
Publisher:
ISBN: 9783848724925
Category :
Languages : en
Pages : 1314
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Book Description
