Abstract

This book provides a comparative analysis of domestic laws on contracts and sales in over sixty countries to deliver a global view of domestic and international sales law. The book reports on the real practice of sales law, taking into account present-day problems. Complex questions on the obligations under a sales contract, the ways in which these are established, as well as the remedies following the breach of obligations, are all discussed. The book encompasses all aspects of a sale of goods transaction and takes a wide view of sale by including general contract law. Since the first edition, new case law and legislation have emerged changing the content of the law on contracts and sales in some countries, and changes to the law of contract have been implemented in Argentina, France, Hungary, and Japan. Additionally, there have been 16 further country adoptions of the CISG. The UNIDROIT PICC was updated in 2016, and the ICC released new editions of its INCOTERMS© and force majeure and hardship clauses in 2020. International or multilateral developments that were in prospect (and some which were not) when writing the original edition have now either evolved or disappeared. This new edition provides a fresh comparative analysis of domestic laws and international developments, whilst considering the new case law applying and interpreting uniform projects like the CISG and the UNIDROIT PICC, and the influence this may have in the domestic law on contracts and sales.

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