Product Liability in Comparative Perspective

ISBN-13: 9780521847230 / Angielski / Twarda / 2005 / 378 str.

Duncan Fairgrieve

Opis

This book examines the law in respect of financial redress for those injured by defective consumer items, known as product liability. The different approach of the courts in a variety of different countries is examined, including Western Europe, Accession Countries, North America and Japan. Contributions are made by distinguished commentators, including a high court judge, European Commission official, leading litigators and academics.

Recenzje

'This collection of essays presents a comparative study of product liability. … the book raises a number of questions about the current state of product liability legislation in the EU.' Journal of Consumer Policy

Spis treści

Foreword Sir Michael Burton; 1. Introduction Duncan Fairgrieve and Luis Gonzalez Vaque; Part I. Country Reports: 2. The use of comparative law Michael Brooke, Ian Forrester, Nicholas Underhill and Sir Michael Burton; 3. Spanish product liability today - adapting to the 'new' rules Miquel Martin-Casals; 4. Interaction between the European directive on product liability and the former liability regime in Italy Eleonora Rajneri; 5. L'Exception Francaise? The French law of product liability Duncan Fairgrieve; 6. German product liability law Stefan Lenze; 7. Dutch case law on the EU Cees C. van Dam; 8. Defect in English Law - lessons for the harmonisation of European product liability Geraint Howells; Part II. European Influences: 9. Product liability Hans Claudius Taschner; 10. The development risks defence Mark Mildred; 11. Approaches to product liability in the EU and Member States Christopher Hodges; 12. Product liability - a history Geraint Howells; Part III. Comparing Systems: 13. Harmonisation or divergence? Simon Taylor; 14. Product liability law in Centre Europe and the true impact of the product liability directive Magdalena Sengayen; 15. Bugs in Anglo-American products liability Jane Stapleton; 16. Comparing product safety and liability law in Japan Luke Nottage; Appendix.