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This book examines the law of product liability from a comparative perspective. With the European Directive on Product Liability enacted over 20 years ago, this publication analyses the state of product liability in a number of key jurisdictions including both Western European countries and New Member States. Account is also taken of developments further afield, including the United States and Japan. Distinguished contributors, including a high court judge, European Commission official, leading litigators and academics, provide individual country reports and a number of integrated comparative studies. The book is designed for practical use by legal practitioners, academics, students and others interested in the area of contract, tort, civil procedure and multi-party litigation. In particular, practitioners will find the country reports an essential reference point.
Tort and negligence --- European Union --- Products liability --- Products liability. --- 351.82*7 <4-15> --- Consumentenrecht--West-Europa --- 351.82*7 <4-15> Consumentenrecht--West-Europa --- Manufacturers' liability --- Product liability --- Tort liability of manufacturers --- Liability (Law) --- Law and legislation --- Law --- General and Others --- Products liability - Europe --- Products liability - European Union countries
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Examining the topical sphere of governmental liability in damages, this work argues that there has been an important shift in the traditional English law approach as illustrated in a series of House of Lords decisions.
Government liability --- Law - Non-U.S. --- Law, Politics & Government --- Law - Europe, except U.K. --- Crown proceedings --- Government immunity --- Government responsibility --- Liability, Government --- Liability, Public --- Liability of the state --- Public liability --- Sovereign immunity --- State liability --- State responsibility --- Tort liability of the government --- Tort liability of the state --- Administrative law --- Administrative responsibility --- Constitutional law --- Liability (Law) --- Misconduct in office --- Public law --- Torts --- Act of state --- Constitutional torts --- State action (Civil rights) --- Law and legislation
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This book provides a comparative study of contract law, examining the interaction of common law and civil law approaches to contract law. Drawing extensively upon English, French and European law, the book explores how the law of contract of Jersey, Channel Islands, has been influenced by both civil law and common law sources. It is argued that this jurisdiction is a striking example of comparative law in action, given that Jersey contract law is made up of a blend of common law and civil law approaches. Jersey law is premised upon a subjective approach to contracts, in which civil law concepts such as cause (rather than consideration) and vices de consentement are the foundational aspects, but is nonetheless highly influenced by the common law in areas such as remedies (damages, termination, etc). The book analyses a series of key issues from a comparative and European perspective, including the principles underlying contract law (comparing and contrasting civil and common law approaches), the formation of contract, requirements of reciprocity (cause vs consideration), the structure and approach of precontractual liability, the role of good faith in a mixed system, the architecture of remedies, and more
Contracts --- Law --- English influences. --- French influences.
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Comparative law --- Droit comparé --- Procédure (droit) --- Droit international privé --- Tribunaux --- Comparative law. --- Comparative jurisprudence --- Comparative legislation --- Jurisprudence, Comparative --- Law, Comparative --- Legislation, Comparative --- Droit comparé. --- Droit international privé. --- Tribunaux. --- France --- Italie --- Allemagne --- Canada --- Royaume-Uni --- Pays-Bas --- Espagne --- Malaisie --- Suisse --- Afrique du Sud --- Portugal --- Philippines --- Israël --- Argentine --- Etats-Unis --- Singapour --- Brunei --- Turquie
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This work provides comprehensive analysis of product liability under the common law of negligence, the strict liability provisions of the Consumer Protection Act 1987, and the EU's Product Liability Directive, placed in the context of the international and transnational legal framework.-- Provided by publisher.
Products liability. --- Manufacturers' liability --- Product liability --- Products liability --- Tort liability of manufacturers --- Liability (Law) --- Law and legislation
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Administrative responsibility --- Government liability --- Personal liability of public employees --- Responsibility, Administrative --- Tort liability of public employees --- Administrative law --- Liability (Law) --- Government immunity --- Government responsibility --- Liability, Government --- Liability, Public --- Liability of the state --- Public liability --- Sovereign immunity --- State liability --- State responsibility --- Tort liability of the government --- Tort liability of the state --- Constitutional law --- Misconduct in office --- Public law --- Torts --- Act of state --- Constitutional torts --- State action (Civil rights) --- Law and legislation
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Class actions (Civil procedure). --- Complex litigation. --- Exterritoriality. --- Conflict of laws --- Civil procedure.
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