Vernon V. Palmer

Approximately 150 million people worldwide live in legal systems in which there is both a common law and a civil law content, yet there has been little comparative study of the experience of these 'mixed jurisdictions'. Here, the author considers these jurisdictions in a comparative framework, which includes their founding and raisons d'être, as well as the cultural divisions of the jurists and the evolutionary tendencies of their common and civil law components. In addition, he examines the internal contradictions between Anglo-American judicial institutions, methodologies and procedures, and the substantive civil law. The book argues that the legal systems of such far-flung and diverse cultures as the Philippines, Quebec, Scotland and South Africa have many unique and fruitful points of comparison. The conclusion is that these mixed jurisdictions form a closely related 'Third Legal Family' with cohesive traits and tendencies.

The Third Legal Family

Mixed Jurisdictions Worldwide

Franz Werro

"In the light of twelve reports from different European jurisdictions, the present volume offers case studies covering among others liability of parents, of employers, of property owners, medical liability, product liability, and motorist liability. Achieving an unprecedented synthesis, this book should be of interest not only to those who work on European law reform projects, but also to those who practice private tort law and seek a better understanding of the foundations of liability, both on a national and an international level."--BOOK JACKET.Title Summary field provided by Blackwell North America, Inc. All Rights Reserved

The Boundaries of Strict Liability in European Tort Law

This is the first comprehensive work to capture the rise of moral damages (non-pecuniary loss) in European contract law through a historical and comparative analysis. Unique features of this study include the first classification scheme of the systems into liberal, moderate and conservative regimes, a taxonomy of non-pecuniary loss drawn from a European-wide jurisprudence, and a comprehensive bibliography of the subject. Written by a leading academic on comparative law, Palmer's precise and practical insights on Europe's leading cases will be of great interest to academic researchers and practitioners alike.

The Recovery of Non-Pecuniary Loss in European Contract Law

A pioneering work capturing the recent rise of moral damages in modern European contract law.

Vernon V. Palmer

Books

Your next favorite book is out there