TY  - BOOK
AU  - Lars Meyer
PY  - 2021
CY  - Berlin, Germany
PB  - Peter Lang Verlag
TI  - Non-Performance and Remedies under International Contract Law Principles and Indian Contract Law
T2  - A comparative survey of the UNIDROIT Principles of International Commercial Contracts, the Principles of European Contract Law, and Indian statutory contract law
UR  - https://www.peterlang.com/document/1135643
N2  - The survey compares the rules on contractual non-performance and remedies under the UNIDROIT Principles of International Commercial Contracts, the Principles of European Contract Law, and Indian statutory contract law (including the Indian Contract Act, 1872). Given that most Indian statutes were derived from English law and may therefore be viewed as «codified common law», this comparison may contribute to the question of whether, especially in view of contract law harmonisation in the EU, the civil-law and common-law traditions could be merged in a common code. Moreover, it may help identify legal differences that are relevant to doing business between India and Europe. The general conclusion of the survey is that the Principles and Indian statutory contract law share a close proximity especially because many of their provisions on non-performance and remedies appear to be derived from the same concepts and also provide for very similar consequences.
KW  - Indisches Recht, Indian Contract Act, Vertragsrecht, Grundregeln des Europäischen Vertragsrechts
LA  - English
ER  -