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This book investigates how thirteen European legal systems solve twelve case studies about mistake, fraud or duties to inform in contract law. After considering the historical origins of these legal concepts, national reports explain each system’s solution. Comparative observations synthesize and evaluate the national rules. The book demonstrates that significant differences exist in how contract law works in European jurisdictions and that although the solutions proposed are often similar, divergent values underlie the legal rules.
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This book investigates how thirteen European legal systems solve twelve case studies about mistake, fraud or duties to inform in contract law. After considering the historical origins of these legal concepts, national reports explain each system’s solution. Comparative observations synthesize and evaluate the national rules. The book demonstrates that significant differences exist in how contract law works in European jurisdictions and that although the solutions proposed are often similar, divergent values underlie the legal rules.