Unification Of Tort Law: Liability For Damage Caused By Others
J. Spier, Francesco Donato Busnelli
Kluwer Law International, 2003 - 335 Seiten
The foundations of tort law and the law of damages differ considerably in the various European legal systems. Until recently, there was no attempt to harmonize this important field in a consistent and comprehensive manner. A group of tort law experts, the European Group of Tort Law, is currently engaged in systematically researching the most fundamental questions of many European and several non-European legal systems. This research has resulted in a series of books, notably on Wrongfulness, Damages, Causation, Strict Liability and the present volume. Volumes on Contributory Negligence, Fault and Multiple Tortfeasors are forthcoming. The series is intended as a contribution to a common law of Europe.
in this volume, the authors provide an overview of liability for others (vicarious liability) seen from the angle of their respective legal systems. The concept of this type of liability is further examined in analyses of a variety of cases and fact-patterns. This volume also contains a comparative report that summarizes and compares the most important elements identified in the individual country reports.
This volume shows the common grounds of liability for others in the various legal systems examined. It provides a wealth of information and insights on fundamental issues of liability for others, which will greatly benefit both legal scholars and practitioners.