Abstract
This chapter tries to determine whether English law is right to adopt an individualist attitude, or whether it should shift towards the German position, which is generally representative of most continental legal systems. It provides some background information on the ‘European’ principles of contract law, and then identifies the actual differences between ‘European’ and English laws. It also describes the provisions on mistake and non-disclosure of fact that are found in the Principles of European Contract Law (PECL). This chapter also discusses English and German cases related to the law on mistake and non-disclosure of fact.
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