-
Changing Contract Lenses: Unexpected Supervening Events in English, New Zealand, U.S., Japanese, and International Sales Law and Practice
- Indiana Journal of Global Legal Studies
- Indiana University Press
- Volume 14, Issue 2, Summer 2007
- pp. 385-418
- 10.2979/gls.2007.14.2.385
- Article
- Additional Information
Abstract
This article compares differences in the reasoning underlying contractual relationships between English and New Zealand law and U.S. and Japanese law. It then builds upon an existing framework by adding the notion of didactic formality to identify another important contrast between the laws of these countries. It also discusses how CISG and UPICC fit in to this spectrum. The article concludes by questioning "strong convergence" theory in commercial law worldwide.
collapse
You are not currently authenticated.
If you would like to authenticate using a different subscribed institution or have your own login and password to Project MUSE
Authenticate
