Abstract

Abstract This chapter first considers civil law jurisdictions and various international legal instruments and their approach to the construction of contracts. In particular, the chapter focuses on the objective/subjective debate and the admissible evidence. It then looks at the international restatements of contract law, which are committed to a subjective theory of contract, such as is found in civil law countries. Next, the chapter considers a more theoretical perspective in the topic of contractual interpretation, and introduces the relevant literature to that effect. Such wider perspectives have been a source of recent developments—and may continue to be the source of future developments—in this field.

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