This book examines uniform contract law in all 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. The author suggests ways to overcome these obstacles, and develops an autonomous methodology of interpretation of transnational contract principles. The book analyses existing uniform transnational law rules, such as the UNIDROIT Principles of International Commercial Contracts.
|Publisher:||Springer Berlin Heidelberg|
|Edition description:||Softcover reprint of hardcover 1st ed. 2007|
|Product dimensions:||6.10(w) x 9.25(h) x 0.24(d)|
Table of ContentsGeneral aspects of uniform private law: Jurisprudential categories and purpose.- Diversity in the law.- Unity through uniform private law.- 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.- 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.