Comparative Contract Law: England, France, Germany

Author: P. D. V. Marsh
Published: June 2005
Publisher: Ashgate Publishing, Limited
ISBN: 0566090066
Hardcover Book
Number of Pages: 356

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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. As the only single-volume treatment of French and German contract law in the English language, this book will be invaluable to British businesses trading with France and Germany, to lawyers who may be called upon to advise such businesses and to professionals in the construction industry who may be carrying out work in France or Germany.

Table of Contents
Preface
List of works cited by author only
List of cases
List of statutes
List of abbreviations
1 Historical introduction 1
2 English common law and the civil law systems of France and Germany - primary distinctions 27
3 Essentials of a valid contract 41
4 Termination of offers and withdrawal from negotiations 58
5 Acceptance 69
6 Objet 83
7 Cause and consideration 95
8 Mistake and misrepresentation - English law 112
9 Mistake, fraud and the obligation to inform - French law 121
10 Mistake - German law 133
11 Performance obligations 140
12 Performance obligations under civil law - general 150
13 Contracts for sale - French law 167
14 Contracts for works - French law 183
15 Contracts for sale - German law 205
16 Contracts for works - German law 222
17 Transfer of property and risk 238
18 Reservation of title and transfer of title to third parties 250
19 The contract and third parties: liabilities in contract and tort 268
20 The control of unfair terms 290
21 Remedies and excuses for non-performance 310
Index 351

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