pt. 1. General aspects of uniform private law: jurisprudential categories and purpose. Diversity in the law ; Unity through uniform private law -- pt. 2. Methods of applying uniform private law within domestic legal systems. Performance of payment obligations in the UPICC ; Exemplary application of the UPICC in the context of English law ; Exemplary application of the UPICC in the context of German law -- pt. 3. The UNIDROIT principles in the conflict of laws. Status quo of transnational law in the conflict of laws ; Methods of integration in the general conflict of laws ; Methods of integration through commercial arbitration ; Conclusion
Summary
Examines uniform contract law in relevant areas of legal doctrine and practice and considers the barriers which exist toward it in modern nation states, namely in the German and English legal systems. This work suggests ways in which these barriers can be overcome and develops a methodology of interpretation of transnational contract principles
Analysis
recht
law
internationaal recht
international law
Law (General)
Recht (algemeen)
Bibliography
Includes bibliographical references (pages 217-230)