The EU is active in attempting to harmonize the law of product liability and the sale of goods to consumers, with the aim of promoting fair competition, aiding the internal market, and protecting consumers. But how do the resulting laws relate to existing national laws of liability and compensation? This comparative work considers the French and English laws governing all those who may be liable for products: their producers, their suppliers, their users, and their regulators. It is a revealing case study in the harmonization of laws in Europe, in an area which cuts across the traditional...

This book starts by surveying the use or neglect of good faith in European contract law and traces its historical origins. Its central part takes thirty hypothetical situations that have attracted the application of good faith and analyzes them according to fifteen national legal systems. It concludes by explaining how European lawyers, whether from a civil or common law background, need to come to terms with the principle of good faith.

This book starts by surveying the use or neglect of good faith in European contract law and traces its historical origins. Its central part takes thirty hypothetical situations that have attracted the application of good faith and analyzes them according to fifteen national legal systems. It concludes by explaining how European lawyers, whether from a civil or common law background, need to come to terms with the principle of good faith.

Principles of French Law offers a comprehensive introduction to French law and the French legal system in terms which a common lawyer can understand. The authors give an explanation of the institutions, rules and techniques that characterize the major branches of French law. The chapters provide the reader with a clear sense of the questions that French lawyers see as important and how they would answer them.
In the ten years since the publication of the first edition, French law has changed in significant ways. European Union law and the European Convention on Human Rights have had a...

Mass production and changes in distribution chains have severely restricted the power of the seller and the buyer to use their own skill and judgement. As a result, 'product liability' has developed into a distinct area of legal regulation. Traditional legal techniques, such as the warranty against latent defects in contract and fault in tort, proved inadequate safeguards. This examination of western-European legal systems combines legal history and comparative law to demonstrate how tort law has adapted to meet these new conditions.

The French Civil Code, which governs the law of obligations in France, has remained unchanged since 1804 and has served as the model for civil codes across the world. In 2016, the French Government enacted legislation repealing much of this law. This work looks at the effect of this action and the new provisions for French contract law. Drawing on the expertise of comparative lawyers working on French law and the law of other civil codes, it explores the lively debates between French and other scholars on the merits (or demerits) of the reform. It will make these seismic and fundamental...