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Author:
Publisher:
ISBN:
Category : Civil law
Languages : it
Pages : 914
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Book Description
Author:
Publisher:
ISBN:
Category : Civil law
Languages : it
Pages : 914
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Book Description
Author:
Publisher:
ISBN:
Category :
Languages : it
Pages : 394
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Author:
Publisher:
ISBN:
Category :
Languages : it
Pages :
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Author:
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ISBN: 9788813228910
Category : Law
Languages : it
Pages :
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Author: [Anonymus AC00955680]
Publisher:
ISBN: 9788813203146
Category : Law
Languages : it
Pages :
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Author: Richard Hyland
Publisher: Oxford University Press
ISBN: 0199711097
Category : Law
Languages : en
Pages : 731
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Book Description
Gifts: A Study in Comparative Law is the first broad-based study of the law governing the giving and revocation of gifts ever attempted. Gift-giving is everywhere governed by social and customary norms before it encounters the law and the giving of gifts takes place largely outside of the marketplace. As a result of these two characteristics, the law of gifts provides an optimal lens through which to examine how different legal systems engage with social practice. The law of gifts is well-developed both in the civil and the common laws. Richard Hyland's study provides an excellent view of the ways in which different civil and common law jurisdictions confront common issues. The legal systems discussed include principally, in the common law, those of Great Britain, the United States, and India, and, in the civil law, the private law systems of Belgium and France, Germany, Italy, and Spain. Professor Hyland also serves a critique of the dominant method in the field, which is a form of functionalism based on what is called the praesumptio similitudinis, namely the axiom that, once legal doctrine is stripped away, developed legal systems tend to reach similar practical results. His study demonstrates, to the contrary, that legal systems actually differ, not only in their approach and conceptual structure, but just as much in the results.
Author:
Publisher:
ISBN: 9788813210069
Category : Law
Languages : it
Pages :
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ISBN: 9788813222116
Category : Law
Languages : it
Pages :
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Book Description
Author: Viktor Knapp
Publisher: Martinus Nijhoff Publishers
ISBN: 9789024727872
Category : Comparative law
Languages : en
Pages : 820
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Book Description
Author: E. H. Hondius
Publisher: sellier. european law publ.
ISBN: 3935808615
Category : Contracts for work and labor
Languages : en
Pages : 526
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Book Description
The sales contact has served as the paradigm for contracts in general. Moreover, it is also probably the most common contract, and certainly the most common consumer contract that there is. Furthermore, there are many mixed transactions that contain a certain element of sale, such as distribution contracts or all sorts or manufacturing contracts. This book presents the rules regarding sales contracts under European law. The principles examined here start from the idea of a uniform regime for all kind of sales transactions. Moreover, these principles aim to meet the needs of international and national commerce alike and attempt to create a truly uniform sales law, bridging the differentiation into different settings, different parties to the contract, and different object of sales. However, when deemed necessary, certain provisions are declared mandatory in consumer sales in order to protect the weaker party in the transaction involved. To that end, a balance is struck between the two major international instruments in this area, the CISG (Contracts for the International Sale of Goods) and the Consumer Sales Directive. Moreover, during the drafting process, comparative material from over 20 different EU Member States has been taken into account. The work is not only a presentation of a future model for European rules to come, but also provides a fairly detailed indication of the present legal situation in the Member States.
