It is dangerous to make assumptions about another countrys law peter marshs 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. Roman law origins 1 the reception of roman law 3 the codification of french law 8 german law and its codification 13 the english law of contract 18 2 english common law and the civil law systems of france and germany primary distinctions 27 divisions of the law 27 conceptualism and pragmatism 33 sources of law 34 doctrine 37. Comparative contract law england france germany p d v marsh 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. Mistake over the terms of a contract a comparative analysis of england france and germany a comparative analysis of england france and germany the doctrine of mistake within contract law has been an important development for providing relief in preventing a contract from forming or to set aside or to rectify a document when it may . Bibliography includes bibliographical references and index publishers summary an comparison of contract law in england france and germany source nielsen book data 9780566090066 20160527
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