- Copyright Page
- Preface to the Second Edition
- Preface to the First Edition
- Notes on the Contributors
- Abbreviations
- Comparative Law Before the <i>Code Napoléon</i>
- Development of Comparative Law in France
- Development of Comparative Law in Germany, Switzerland, and Austria
- Development of Comparative Law in Italy
- Development of Comparative Law in Great Britain
- Development of Comparative Law in the United States
- Comparative Law in Central and Eastern Europe
- The Development of Comparative Law in Japan
- The Development of Comparative Law in Modern China
- Development of Comparative Law in Latin America
- Comparative Law and Comparative Knowledge
- Comparative Law in Legal Education
- The Functional Method of Comparative Law
- Comparative Law: Study of Similarities or Differences?
- Comparative Legal Families and Comparative Legal Traditions
- Comparative Law, Transplants, and Receptions
- Comparative Law and the Study of Mixed Legal Systems
- Comparative Law and its Influence on National Legal Systems
- Comparative Law and European Union Law
- Comparative Law and the Europeanization of Private Law
- Globalization and Comparative Law
- Comparative Law and the Islamic (Middle Eastern) Legal Culture
- Comparative Law and African Customary Law
- Comparative Law and Language
- Comparative Law and Legal Culture
- Comparative Law and Religion
- Comparative Law and Legal History
- Comparative Law and Socio-Legal Studies
- Comparative Law and Critical Legal Studies
- Comparative Law and Economic Analysis of Law
- New Directions in Comparative Law
- Sources Of Law and Legal Method in Comparative Law
- Comparative Contract Law
- Comparative Sales Law
- Unjustified Enrichment in Comparative Perspective
- Comparative Tort Law
- Comparative Property Law
- Comparative Succession Law
- Comparative Family Law
- Comparative Labour Law
- Comparative Company Law
- Comparative Competition Law
- Comparative Constitutional Law
- Comparative Law and Human Rights
- Comparative Administrative Law
- Comparative Criminal Law
- Comparative Civil Procedure
- Comparative Law And Private International Law
- Index
Abstract and Keywords
The story of comparative law in the field of sales contracts is inextricably linked to Ernst Rabel. Rabel not only prepared the basis for any comparative study of the modern law of sales in his epochal treatise ‘Das Recht des Warenkaufs’, but also initiated the process of world-wide harmonization of the law of international sales. This process has not only led to one of the most important international conventions in the field of private law (the 1980 UN Convention on Contracts for the International Sale of Goods—CISG) but has also become a highly influential factor in the field of comparative sales law in the twentieth century. The article first outlines the most important projects in this area and their interaction with comparative law. It then goes on to discuss selected characteristic features of the law of sales which are interesting from a comparative point of view.
Keywords: CISG, comparative law, Ernst Rabel, sales contract, uniform sales law
Peter Huber is Professor of Private Law, Conflict of Laws, and Comparative Law, Johannes Gutenberg University, Mainz
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- Copyright Page
- Preface to the Second Edition
- Preface to the First Edition
- Notes on the Contributors
- Abbreviations
- Comparative Law Before the <i>Code Napoléon</i>
- Development of Comparative Law in France
- Development of Comparative Law in Germany, Switzerland, and Austria
- Development of Comparative Law in Italy
- Development of Comparative Law in Great Britain
- Development of Comparative Law in the United States
- Comparative Law in Central and Eastern Europe
- The Development of Comparative Law in Japan
- The Development of Comparative Law in Modern China
- Development of Comparative Law in Latin America
- Comparative Law and Comparative Knowledge
- Comparative Law in Legal Education
- The Functional Method of Comparative Law
- Comparative Law: Study of Similarities or Differences?
- Comparative Legal Families and Comparative Legal Traditions
- Comparative Law, Transplants, and Receptions
- Comparative Law and the Study of Mixed Legal Systems
- Comparative Law and its Influence on National Legal Systems
- Comparative Law and European Union Law
- Comparative Law and the Europeanization of Private Law
- Globalization and Comparative Law
- Comparative Law and the Islamic (Middle Eastern) Legal Culture
- Comparative Law and African Customary Law
- Comparative Law and Language
- Comparative Law and Legal Culture
- Comparative Law and Religion
- Comparative Law and Legal History
- Comparative Law and Socio-Legal Studies
- Comparative Law and Critical Legal Studies
- Comparative Law and Economic Analysis of Law
- New Directions in Comparative Law
- Sources Of Law and Legal Method in Comparative Law
- Comparative Contract Law
- Comparative Sales Law
- Unjustified Enrichment in Comparative Perspective
- Comparative Tort Law
- Comparative Property Law
- Comparative Succession Law
- Comparative Family Law
- Comparative Labour Law
- Comparative Company Law
- Comparative Competition Law
- Comparative Constitutional Law
- Comparative Law and Human Rights
- Comparative Administrative Law
- Comparative Criminal Law
- Comparative Civil Procedure
- Comparative Law And Private International Law
- Index