Applicability, Similarities, Differences among CISG, UPICC and PECL; And the Binding Nature of the Concept of Good Faith under These Instruments

Abstract

This essay discusses the applicability of the United Nations (UN) Convention on Contracts for the International Sales of Goods (CISG); the International Institute for the Unification of Private Law’s (UNDROIT) Principles of International Commercial Contracts (UPICC); and the Principles of European Contract Law (PECL).It also elucidates the similarities and differences among these three instruments; and evaluates whether the concept of good faith becomes binding by the virtue of application of the instruments.