Comparative Contract Law and Economics provides a deeper understanding of the similarities and differences between the legal systems of France, England, the US and Germany in terms of contract law.
The application of the economically inspired optimal model rule as a uniform term of comparison provides valuable insights into the pre-contractual duties of disclosure, the phenomena of unforeseen contingencies and the unilateral termination of contracts. The objective evaluation method enriches traditional comparative contract law by enabling further qualitative assessment. The book offers ample opportunities for further research and for `better' law making, legislation and jurisprudence. Moreover, it enables comparative contract law to offer clear-cut, objective recommendations on the possible improvements of legal rules or decisions.
This well-documented book will appeal to postgraduate students and scholars of law and economics, and comparative law. Judges and law practitioners will also find much to interest them in this pioneering volume.