What happens when contracting parties do not expressly provide for a particular situation in their agreement? Is intervention by the courts or legislature to fill gaps in contracts justified? How should those gaps be filled? This book is unique in the way it combines comparative and theoretical perspectives to provide answers to these questions. From a comparative law perspective, relatively little attention has been given to the different interpretative and gap filling techniques available in different legal systems. A comparison of the approach to contract interpretation and gap filling in...