Compensation for Personal Injury in English, German and Italian Law: A Comparative Outline
Cambridge University Press, Feb 24, 2005 - Law
Cross-border claims for personal injuries are becoming more common. Furthermore, European nationals increasingly join class actions in the USA. These tendencies have created a need to know more about the law of damages in Europe and America. Despite the growing importance of this subject, there is a dearth of material available to practitioners to assist them in advising their clients as to the heads of damage recoverable in other countries. This book aims to fill that gap by looking at the law in England, Germany and Italy. It sets out the raw data in the wider context of tort law, then provides a closer synthesis, largely concerned with methodological issues, and draws some comparative conclusions.
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19 February accident American amount annuity April assessment award Basil Markesinis BGHZ calculation Cass claim claimant common law comparative compensation Corte di Cassazione costs Court of Appeal danno biologico danno morale December decision defendant disability Dow Corning employer employment English law entitled European fact February Federal Court future loss German law giur heading of damage Health Authority HL(E income Italian Italian law January judge judgment law of damages lawyers liability Limitation Act 1980 limitation period litigation Lord loss of amenity loss of earnings lump sum NJW-RR non-pecuniary damages November October OLG Frankfurt OLG Koln paid pain and suffering payments pecuniary pension personal injury PIQR plaintiff principle quadriplegia reasons recover recoverable result rules social security carrier South Yorkshire Police subrogation taken into account tort law tortfeasor trial VersR victim wrongdoer