Comparative Contract Law: England, France, Germany

Front Cover
Gower, 1994 - Law - 356 pages
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 make assumptions about another country's law. Peter Marsh's book reviews and compares the main elements of English, French and German law as they relate to business contracts, especially contracts for the sale of goods and for construction work. He examines the formation of contracts, their validity, the obligations of the parties, the position of third parties, the control of unfair terms, and remedies for non-performance. By tracing current law back to its historical roots he also shows how both the similarities and the differences have developed and how one legal system could still learn from another.

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English common law and the civil law systems of France and Germany
Essentials of a valid contract
Termination of offers and withdrawal from negotiations

17 other sections not shown

Common terms and phrases

Bibliographic information