000 01950nam a22002291i 4500
005 20220507164830.0
008 161216s2016 enk ob 001 0 eng d
020 _a9781782257240
040 _aMAIN
082 0 0 _a346.423/41022
100 1 _aFairgrieve, Duncan,
245 1 0 _aComparative law in practice :
_bcontract law in a mid-channel jurisdiction
_h[electronic resource] /
_cDuncan Fairgrieve.
300 _a1 online resource.
500 _aBloomsbury Pub Ebook
504 _aIncludes bibliographical references and index.
520 8 _aThis book provides a comparative study of contract law, examining the interaction of common law and civil law approaches to contract law. Drawing extensively upon English, French and European law, the book explores how the law of contract of Jersey, Channel Islands, has been influenced by both civil law and common law sources. It is argued that this jurisdiction is a striking example of comparative law in action, given that Jersey contract law is made up of a blend of common law and civil law approaches. Jersey law is premised upon a subjective approach to contracts, in which civil law concepts such as cause (rather than consideration) and vices de consentement are the foundational aspects, but is nonetheless highly influenced by the common law in areas such as remedies (damages, termination, etc). The book analyses a series of key issues from a comparative and European perspective, including the principles underlying contract law (comparing and contrasting civil and common law approaches), the formation of contract, requirements of reciprocity (cause vs consideration), the structure and approach of precontractual liability, the role of good faith in a mixed system, the architecture of remedies, and more
650 0 _aContracts
650 0 _aLaw
650 0 _aLaw
856 4 0 _uhttps://doi.org/10.5040/9781782257240?locatt=label:secondary_bloomsburyCollections
942 _cEBK
999 _c17520
_d17520