Mixed Legal Systems in Comparative Perspective: Property and Obligations in Scotland and South Africa

ISBN-13: 9780199271009 / Angielski / Twarda / 2005 / 954 str.

Reinhard Zimmermann; Daniel Visser; Kenneth Reid

Opis

Scotland and South Africa are two of the leading jurisdictions which integrate English common law with Continental civil law. This volume examines their experience and considers the sider lessons both for mixed legal systems and for the development of a European private law.

Recenzje

This splendid volume, the product of some fifty jurists of largely Scottish and South African origins, under the guidance of Reinhard Zimmermann, Daniel Visser and Kenneth Reid, is testimony to the remarkable resilience of major, transnational legal traditions and their ability to survive and prosper in the face of colonialist and nationalist restraints...The book is devoted to substantive private law and is devided into three Parts, treating successively Contract (the largest Part), Delict and other Obligations arising by Law, and Property...The main interest of the volume for South African and Scottish lawyers..will be in the deailed, comparative reflection on the content of each national law...this book is significant and welcome..

O autorze

Reinhard Zimmermann is Director of the Max-Planck-Institute of Comparative Private Law and Private International Law in Hamburg, and Professor of Private Law, Roman Law and Comparative Legal History at the University of Regensburg. Kenneth Reid is Professor of Property Law at the University of Edinburgh, and has been a Scottish Law Commissioner since 1995. Daniel Visser is Professor in the Faculty of Law at the University of Cape Town.