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For some Western European legal systems the principle of good faith has proved central to the development of their law of contracts, while in others it has been marginalized or even rejected. This book starts by surveying the use or neglect of good faith in these legal systems and explaining its historical origins. The central part of the book takes thirty situations which would, in some legal systems, attract the application of good faith, analyses them according to fifteen national legal systems and assesses the practical significance of both the principle of good faith and its relationship to other contractual and non-contractual doctrines and forms of regulation in each situation. The book concludes by explaining how European lawyers, whether from a civil or common law background, may need to come to terms with the principle of good faith. This was the first completed project of The Common Core of European Private Law launched at the University of Trento.
• Germanic, Greek, French, Common Law systems and Nordic law systems are the five main legal families treated which means that the book will be of use to all contract lawyers interacting with these systems • Thirty case studies are examined from the point of view of fifteen jurisdictions with both interim and final general comparative conclusions which means that this books offers a wealth of original comparative law material for the contemporary researcher • Users can learn how a national lawyer tackles a contract case from their own particular country and then see the same case answered from another jurisdiction which means that the book should have significant teaching application