Comparative Contract Law: England, France, Germany
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
acceptance according action agreed agreement allowed appears apply breach building Cass cause circumstances claim clause client Code Civil common completion considered constitute construction contained contract contractor Cour de cassation court creditor damages debtor decided decision default defects delivery determined distinction doctrine droit effect employer English law entitled essential established event example exercise existence express extended fact failure faith fault French law further German law give given guaranty held important included intention issue January judgement liability limited loss March materials matter means mistake nature negotiations normally objective obligation offer original particular party passes performance period person position practice principle professional purchaser question reasonable referred regards relating remedy respect responsible result risk Roman law rule seller specific standard supplier supply third party tort unless valid void