Modernising Civil Liability Law In Europe China Brazil And Russia Texts And Commentaries
Publisher: Cambridge University Press
Published: 2011
Language: eng
Number of pages: 274
ISBN-13: 9781107007796
Description: "Non-contractual liability, stemming from damage accountably caused to another, has been the subject of the PETL and DCFR-VI European reform initiatives. Gert Brüggemeier, however, proposes alternative reforms which, instead of trying to overcome the differences between civil law (delict) and common law (torts), are restricted to civil liability. The focus is on the grounds of accountability, and stricter forms of liability are at the fore. Quasi-strict enterprise liability is introduced to fill the lacuna between personal fault and forms of strict liability. A commentary is included on recent legislation on civil liability in China, Brazil and Russia to demonstrate how these large countries try to come to grips with the challenges of 'risk society'"--