Subjects:

Comparative Law

Contents:

Preface

Part 1 Introduction

2. The Liability Systems--A functional Ordering

Part 2: The National Contributions

1. Japan

2. Croatia

3. Quebec

4. United States

5. Canada

6. Israel

7. South Africa

8. Poland

9. Denmark

Part 3

1. Surveying the Results

2. General Conclusions

Pure economic loss is one of the most-discussed problems in the fields of tort and contract. How do we understand the various differences and similarities between these systems and what is the extent to which there is a common-core of agreement on this question? This book takes a comparative approach to the subject, exploring the principles, policies and rules governing tortious liability for pure economic loss in a number of countries and legal systems across the world.

The countries covered are USA, Canada, Japan, Israel, South Africa, Japan, Romania, Croatia, Denmark and Poland, with the contributors taking a comparative fact-based approach through the use of hypothetical problems to analyze and then summarize the individual country's tort approach.Using a fact-based questionnaire, a tested taxonomy, and a sophisticated comparative law methodology, the authors convincingly demonstrate that there are liberal, pragmatic and conservative regimes throughout the world.

The recoverability of pure economic loss poses a generic question for these legal systems - it is not just a civil law versus common law issue. It will be of interest to students and academics studying tort law and comparative law in the different countries covered.