Thomas Kadner Graziano, COMPARATIVE CONTRACT LAW: CASES, MATERIALS AND EXERCISES Basingstoke: Palgrave Macmillan (www.palgrave.com), 2010. xvii + 510 pp. ISBN 9780230579798. £34.99.
| Author | Martin Hogg |
| DOI | 10.3366/elr.2010.0314 |
| Published date | 01 September 2010 |
| Date | 01 September 2010 |
| Pages | 527-529 |
We are living in the age of comparative law. Contract is being taught to students with the Draft Common Frame of Reference (DCFR) and Principles of European Contract Law (PECL) in mind, and often by reference to national solutions adopted in France, Germany, the USA, South Africa, and elsewhere. Any judgment of the new Supreme Court raising a question of the development of the common law, or even sometimes the application of legislation, comes with a considered analysis of how the matter in question would be dealt with in other jurisdictions. Frustratingly for scholars, however, finding appropriate and comprehensible comparative source materials can still be a laborious process. The present work will be very useful in assisting with that task.
The work has a number of strengths, and one principal weakness. Its strengths lie in the breadth of jurisdictions chosen for inclusion, in the helpful dual-language legislative and case entries (as well as excerpts from English language academic commentary), and in the scenarios chosen against which to test the comparative...
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