The victim of a breach of contract may resort to one or more of
four remedies: specific enforcement, compensation, refusal to
perform, and termination. The availability of these remedies may
depend on the fault of the party alleged to be in breach. The book
discusses these topics from a comparative perspective. The
principle contrast is between civil and common law solutions.
Contrasts within each group of systems are also pursued, in
particular, those between English and American common law and those
between French and German civil law. Some related and hybrid
systems are also discussed, as are conventions on international
sale of goods. The aim is not to give a detailed analysis of
particular systems, but rather to identify types of solutions and
to consider how far differences in theoretical approach are
reflected in practical results.
General
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