Providing a comprehensive and comparative analysis of the legal approach to key areas of law within different legal systems, this book offers a blueprint for comparative legal study by evaluating the current epistemological debate on comparative law and comparative legal research methods.

Substantive law, the law of obligations, commercial and corporate law within the major legal systems of the world are all examined and compared. While France and Germany are generally used as the archetypal civil law jurisdictions and English law as the main common law comparator, this third...