Abstract:
In this article I adopt a comparative law approach to illustrate the coexistence of various models governing the sale of goods, and their classification on the basis of two main characteristics: the transfer of property and the opposition certainty/flexibility. I use this approach to analyse the United Nations Convention on Contracts for the International Sale of Goods. Then I examine how the CISG influenced several national systems and can influence future attempts at regional harmonisation. I conclude with the reasons that in my opinion make the CISG a good model for the sale of goods (prestige, equilibrium and derogability), and with the desirable future developments.
Chianale, Angelo, The CISG as a Model Law: A Comparative Law Approach (March 1, 2016). Singapore Journal of Legal Studies, p 29, Mar 2016.
First posted 2016-04-12 06:43:53
Leave a Reply