The Liability of Public Authorities in Comparative Perspective


Book Description

This study explores the understanding of the law of extra-contractual liability as it applies to public authorities in the legal systems of Europe (and selected non-European jurisdictions).




Tort Liability of Public Authorities in Comparative Perspective


Book Description

This book examines the law on compensation for administrative wrongdoing from a comparative law perspective. Particular account is taken of the increasing influence of human rights law, European Community law and international law.




Tort Liability of Public Authorities in European Laws


Book Description

Administrative law permeates all areas of law, and this series focuses on its role both regionally and globally. This volume considers tort liabilities in European public authorities. It looks at several European countries, using case studies to compare administrative laws across the EU.




Vicarious Liability in Tort


Book Description

Vicarious liability is controversial: a principle of strict liability in an area dominated by fault-based liability. By making an innocent party pay compensation for the torts of another, it can also appear unjust. Yet it is a principle found in all Western legal systems, be they civil law or common law. Despite uncertainty as to its justifications, it is accepted as necessary. In our modern global economy, we are unlikely to understand its meaning and rationale through study of one legal system alone. Using her considerable experience as a comparative tort lawyer, Paula Giliker examines the principle of vicarious liability (or, to a civil lawyer, liability for the acts of others) in England and Wales, Australia, Canada, France and Germany, and with reference to legal systems in countries such as the United States, New Zealand and Spain.




The Negligence Liability of Public Authorities


Book Description

This is a thorough account of the law on the negligence liability of public authorities, providing practical guidance as well as a clear analysis of this developing area of law.




French Civil Liability in Comparative Perspective


Book Description

The French law of torts or of extra-contractual liability is widely seen as exceptional. For long it was based on a mere five articles of the Civil Code of 1804, but on this foundation the courts and legal scholars have constructed liabilities for fault and strict liability of an extraordinary breadth and significance. While the rest of the general law of obligations (including contract) in the Civil Code was reformed in 2016 by executive ordonnance, this area was left aside, being the subject in 2017 of a proposal by the French Government for the legislative reform of the law of civil liability, a new legislative category to include both contractual and extra-contractual liability. This work considers important aspects of this developing area of French law in a series of essays by French lawyers and comparative lawyers working in French law and other civil law systems. In doing so, it provides insight into the doctrinal thinking and judgments of French lawyers as well as the possible directions in which this area of the law may be developed in the future.




An Introduction to the Comparative Study of Private Law


Book Description

Original sources illustrate and compare the principal doctrines of private law in the United States, England, France, Germany and China.




Corporate Duties to the Public


Book Description

Today's economic and social context demands that corporations - once seen only as private actors - owe duties to the public.




European Tort Law


Book Description

This textbook provides insight into the differences commonalities and mutual influece of the tort law systems of various European jurisdictions, bringing together national tort law, comparative law, EU law, and human rights law.




Government Liability


Book Description