This 2005 examination of twelve case studies about mistake, fraud and duties to inform reveals significant differences about how contract law works in thirteen European legal systems and, despite the fact that the solutions proposed are often similar, what divergent values underlie the legal rules. Whereas some jurisdictions recognise increasing duties to inform in numerous contracts so that the destiny of mistake and fraud (classical defects of consent) may appear to be uncertain, other jurisdictions continue to refuse such duties as a general rule or fail to recognise the need to protect one of the parties where there is an imbalance in bargaining power or information. Avoiding preconceptions as to where and why these differences exist, this book first examines the historical origins and development of defects of consent, then considers the issues from a comparative and critical standpoint.
This 2005 book investigates how thirteen European legal systems solve twelve case studies about mistake, fraud or duties to inform in contract law. After considering the historical origins of these legal concepts, national reports explain each system's solution. Comparative observations synthesise and evaluate the national rules.
Publisher
Cambridge University Press
Publication Date
2005/02
ISBN
9780521844239
Pages
462 p.
Item Type
Book
Format
Hardcover
Unavailable
This product is currently out of stock. Please check back later.
Recently Viewed Items
Related Products
Your cart is full
You can add up to 100 items to your cart. To add more items, please remove some first.