Open AccessJournal Article
Impossibility and Frustration in Sales Contracts
Kiyoshi Igarashi,Luvern V. Rieke +1 more
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This article is published in Washington Law Review.The article was published on 1967-01-01 and is currently open access. It has received 2 citations till now. The article focuses on the topics: Impossibility & Frustration.read more
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Changing Contract Lenses: Unexpected Supervening Events in English, New Zealand, U.S., Japanese, and International Sales Law and Practice
Abstract: This article compares differences in the reasoning underlying contractual relationships between (more formal) English and New Zealand law versus (more substantive) U.S. and Japanese law. It builds upon the framework proposed by Atiyah and Summers by adding the notion of "didactic formality" to identify another important contrast between the laws of these countries. In more formal systems, as in England and New Zealand, stronger didactic formality involves the "law in books" trying to dictate or direct the "law in action", rather than vice versa. The article also discusses how CISG (the UN Sales Convention) and UPICC (UNIDROIT Principles) fit in to this spectrum. The article therefore concludes by questioning "strong convergence" theory in commercial law worldwide.
Journal ArticleDOI
Changing Contract Lenses: Unexpected Supervening Events in English, New Zealand, U.S., Japanese, and International Sales Law and Practice
TL;DR: In this article, the authors compare differences in the reasoning underlying contractual relationships between English and New Zealand law and U.S. and Japanese law and conclude that strong convergence theory in commercial law worldwide.