| Description |
1 online resource (xiv, 442 pages) |
| Contents |
Introduction -- Common law : English law -- Civil law : French and Chilean law -- Harmonisation by inspiration of the general principles of the civil law system and of UNIDROIT -- Harmonisation by adoption of uniform rules : the 1980 Vienna Convention -- Overall conclusion |
| Summary |
This book describes how the international sales of goods have generally been ruled by either English Law or Civil Law, which has often posed problems due to different approaches regarding certain principles and institutions. It clarifies how the Vienna Convention on Contracts for the International Sale of Goods of 11th April, 1980, tried to harmonise these differences with a codification technique, typical of civil law, giving privilege to rules of civil law most of the time, but also introducing institutions from common law, that are not incompatible with civil law. It explains why the general principles of civil law and of UNIDROIT help with this goal of harmonisation, integrating the loopholes of the UN Convention on Contracts for the International Sale of Goods (CISG) during its interpretation. The work demonstrates why codification prevails over common law in the CISG most of the time, giving certitude and sophistication to this matter, which is vital for global commerce |
| Notes |
Originally presented in French as the author's thesis (doctoral)--Université Paris 1, Panthéon-Sorbonne, 2017 |
| Bibliography |
Includes bibliographical references (pages 307-317) |
| Notes |
Description based upon print version of record |
| SUBJECT |
United Nations Convention on Contracts for the International Sale of Goods (1980 April 11) http://id.loc.gov/authorities/names/n82165228
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United Nations Convention on Contracts for the International Sale of Goods (1980 April 11) fast |
| Subject |
Export sales contracts -- International unification
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International law -- Codification.
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International law -- Codification
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| Form |
Electronic book
|
| ISBN |
1527549127 |
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9781527549128 |
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