Contract Law ― A Comparison of Civil Law and Common Law Jurisdictions

his book will undertake a comprehensive but accessible survey and critical analysis of two of the major legal systems of the world, the Common law and Civil law traditions, through the prism of the law of contract.As businesses become increasingly international it can be essential to understand the different legal systems in which one may be operating. This publication seeks to give the student an essential overview of these differences. Contract law is one of the most important genres of private law for business in both consumer and commercial contracts. When international commercial contracts are concluded, the provisions set out in UNIDROT apply. However, when a company is operating within another state the laws of that state will apply to both personal and commercial contracts entered into. This book will examine the differences in the formation, cessation and interpretation of contracts in major Civil law (European) and Common law (UK, Canada and Australia) jurisdictions. There will also be an overview of the EU restatement on the law of contracts and a brief consideration of hybrid systems (i.e., Scotland and Louisiana).