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Vol 21 No 10 Oct/Nov 2016

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Comparative Product Liability

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Geraint Gordon HowellsLecturer in Law, University of Sheffield

ISBN13: 9781855210783
ISBN: 1855210789
Published: August 1993
Publisher: Ashgate Publishing Ltd
Format: Hardback
Price: Out of print



This book provides a grounding in the principles of product liability and examines how they have been tackled by different legal systems. In particular the author looks at European developments against the background of, for example, the United States, where the concern to protect consumers of defective products has led to something of a products liability crisis - large damage awards plus strict liability have meant that it is difficult for some industries to obtain insurance - and New Zealand, where a no fault compensation scheme operates. The book provides an understanding of the process by which European laws are harmonized, by analyzing the European Directive on Product Liability - and assesses how effective the measures taken have been in the European Community and elsewhere.

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Contents:
The fundamentals of product liability; European harmonization; European product liability directive; product liability in the United Kingdom - contract; product liability in the United Kingdom - negligence; United Kingdom's consumer protection act 1987; France - Europe's loser in the product liability stakes?; Germany - minimalist implementation of the directive; Scandinavia - the insurance solution; product liability in the rest of Europe - the impact of the directive; harmony in Europe? United States - birthplace of the product liability phenomemon; United States - the product liability reform debate; Canadian product liability - the middle ground; Australia - radical thinking - traditional reform; New Zealand's accident compensation approach to product liability; Product liability compensation and harmonization - a personal view.