The recent financial crisis has questioned whether existing
contracts may be adapted, terminated or renegotiated as a result of
unexpected circumstances. The question is not a new one. In
medieval times the notion of clausula rebus sic stantibus was
developed to cope with such situations, and Germany introduced the
theory of Wegfall der Geschaftsgrundlage. In England, the
Coronation cases provided one possible answer. This comparative
study explores the possibility of classifying jurisdictions as
'open' or 'closed' in this regard."
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