Gerhard Dannemann

Stefan Vogenauer

European Contract Law unification projects have recently advanced from the Draft Common Frame of Reference (2009) to a European Commission proposal for an optional Common European Sales Law (2011) which is to facilitate cross-border marketing. This book investigates for the first time how CESL and DCFR rules would interact with various aspects of domestic law, represented by English and German law. Nineteen chapters, co-authored by British and German scholars, examine such interface issues for eg pre-contractual relationships, notions of contract, formation, interpretation, and remedies, extending to non-discrimination, third parties, transfers or rights, aspects of property law, and collective proceedings. They go beyond a critical analysis of CESL and DCFR rules by demonstrating where and how CESL rules would interact with neighbouring areas of English and German law before English and German courts, how domestic traditions might influence the application, which aspects might motivate sellers and buyers to choose or reject CESL, and which might serve as model for national legislators. The findings are summarized in the final two chapters.

Interactions with English and German Law

The Common European Sales Law in Context

Reiner Schulze

Jonathon Watson

Bürgerliches Gesetzbuch (BGB) : Article-by-article Commentary

German Civil Code

Volume I: Books 1-3

German Civil Code - Bürgerliches Gesetzbuch (BGB)

Bürgerliches Gesetzbuch (BGB).. Books 1-3: §§ 1-1296, article-by-article commentary. Volume I

A Commentary to the German Civil Code

Bürgerliches Gesetzbuch

B. S. Markesinis

Werner Lorenz

Described in the Cambridge Law Journal as 'an intellectual achievement of the highest order' and 'a landmark in comparative legal studies' Professor Markesinis' book has earned a reputation among scholars and students as a truly monumental work of scholarship. This, the leading work on the subject, will be essential reading for all scholars of tort law, scholars of comparative legal studies and undergraduate students in both areas

The German Law of Obligations

The recently proposed Common European Sales Law is intended to overcome differences between national contract laws. 19 chapters, co-authored by British and German scholars, investigate for the first time how the projected CESL would interact with various aspects of English and German law.

Gerhard Dannemann

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