oa Fundamina : A Journal of Legal History - Toward a European ius commune in tort law : a practical experience
|Article Title||Toward a European ius commune in tort law : a practical experience|
|© Publisher:||UNISA Press|
|Journal||Fundamina : A Journal of Legal History|
|Publication Date||Jan 2006|
|Pages||81 - 92|
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 ..
Article metrics loading...