Abstract
Abstract: This comparative commentary reflects on a number of themes that have emerged from the preceding papers on the liability of expert witnesses in various European systems in the context of the decision of the United Kingdom Supreme Court in Jones v. Kaney. It briefly surveys a number of other Common law jurisdictions before turning to the systems covered in the preceding papers. The nature of the relevant liability regime as falling within the general rules or as part of a specific, witness-focussed set of rules, the nature of the fault standard and the local perception of witness liability as problematic are all noted. Finally brief comments as to the future chances for harmonisation in this area are made.
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