Author(s)

Yue Lang ¹

Affiliation(s)

¹ Yinchuan University of Energy, Yinchuan City, Ningxia, China

Corresponding Author

Yue Lang

ABSTRACT

This essay offers a thorough examination of contract laws across England, Germany, Norway, Italy, and the CISG. It compares the technicalities of contract formation, including the requirements of offer, acceptance, and consideration, as well as principles like good faith. The analysis covers contractual liability, exploring how different legal systems handle non-performance, including the concept of force majeure. Additionally, it discusses various remedies for contract breaches, such as specific performance, termination, and damages, showcasing the diverse legal approaches. The conclusion underscores the importance of understanding these different legal frameworks for effective contract drafting and comparison, highlighting the impact of legal predictability and fairness on fulfilling contractual expectations.

KEYWORDS

Contract Formation, Comparative Law, Contractual Liability, Remedies for Breach, Legal Systems Comparison

CITE THIS PAPER

Yue Lang, Comparative Analysis of Contractual Frameworks: Insights from England, Germany, Norway, Italy, and the CISG. Science of Law Journal (2024) Vol. 3: 124-130. DOI: http://dx.doi.org/DOI: 10.23977/law.2024.030415.

REFERENCES

[1] Cordero Moss G, Lectures of comparative law of contracts, Oslo, September 2004.
[2] Dongli W, Venture capital management risk study, Probe into the Risk of Venture Capital Management, 2000. 
[3] Ishida, Yasutoshi. "What Does" Foreseeable" Mean? The Scope of Damages under CISG Articles 74-77. Reasonability Principle of Foreseeability-We Don't Need a Crystal Ball." JL & Com. 40, 2021.
[4] Lowry, Paul Benjamin, James Gaskin, and Gregory D. Moody. "Proposing the multi-motive information systems continuance model (MISC) to better explain end-user system evaluations and continuance intentions." Journal of the Association for Information Systems 16, no. 7, 2015.
[5] Teachout, Zephyr, and Lina M. Khan. "Market structure and political law: A taxonomy of power." Duke J. Const. L. & Pub. Poly 9, 2014.

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