This is the first introductory text book to European tort law. It brings together national tort law, comparative law, EU law and human rights law, and provides insights into the differences, commonalities and mutual influence of the different tort law systems at work in Europe.
The book examines the recent attempts to harmonize the various systems of tortious liability by the discovery of a new European Ius Commune , and looks beyond the creation of 'common codes' to ask whether it is possible, or desirable to converge the national models.
The first part of the book ('Systems of liability') provides overviews of the state of affairs of the tort law systems of France, Germany and England and the European Union. In a concluding chapter comparisons are made between the rules, the cultures and the policies of the various systems. Finally, the case for a European codification of tort law is being discussed.
The second part ('Requirements of Liability') analyses and compares the requirements for liability in the various tort law systems: protected interests, negligence and unlawfulness, breach of statutory duty, stricter rules of liability, causation, damage, damages and contributory negligence.
The final part ('Categories of Liability') also assumes a comparative and a supranational point of view and shows how the national and European rules are applied in various ways in a number of categories, such as liability of public bodies, liability for defective products, for motor vehicles, for employees, for children and for premises and highways.
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