oa Fundamina : A Journal of Legal History - Toward a European ius commune in tort law : a practical experience

Volume 12 Number 1
  • ISSN : 1021-545X
  • E-ISSN: 2411-7870



Extracted from text ... TOWARD A EUROPEAN IUS COMMUNE IN TORT LAW: A PRACTICAL EXPERIENCE Johann Neethling (University of South Africa) 1 Introduction It is common knowledge that the principles of tort law (or the law of delict) in various European countries differ considerably. The traditional differences between the casuistic common-law approach in England (and other countries that remain close to that system) and the generalising approach of the continental civil-law countries are well-known.1 Moreover, even civil-law countries, such as France and Belgium on the one hand, and Germany and Austria on the other, differ fundamentally as far as particular aspects of ..

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