An Introduction to Comparative Law

This is the English version of the third (1996) German edition. It is fully revised and updated, some chapters being added and others dropped, but the familiar structure and easy style remain much the same. Firstly, the book discusses the nature of comparative law, its functions, aims, methods and history, then it surveys the main features of the major legal families of the world. In the second part the book provides a model of comparative law in action, comparing, contrasting and evaluating the different approaches (and the less different solutions) to problems of the law of obligations in the major systems of private law. In addition to offering a grounding in comparative private law, the book may also be used as a base for further research.