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European Contract Law and German Law

European Contract Law and German Law

Hardcover

General Law

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ISBN10: 9041125884
ISBN13: 9789041125880
Publisher: Kluwer Law International
Published: Feb 5 2014
Pages: 864
Weight: 3.03
Height: 1.81 Width: 6.14 Depth: 9.21
Language: English
The newest volume in Kluwer's series of comparative analyses of Member State law and the Principles of European Contract Law (PECL), this book not only provides a comparison of the PECL with German law, but also takes into account the Draft Common Frame of Reference (DCFR). The latter incorporates the PECL and adds special rules that respond to current needs, notably in the area of consumer protection. Using a straightforward comparative method, the analysis reveals a significant area of convergence but also highlights the main differences between the PECL, the DCFR and German contract law. The reasons for these differences, both legal and non-legal (historical, social, economic), are clearly set forth.

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