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Company Directors: Duties, Liabilities and Remedies

Edited by: Mark Arnold KC, Simon Mortimore KC
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Pure Economic Loss: New Horizons in Comparative Perspectives


ISBN13: 9780415775649
Published: October 2008
Publisher: Routledge-Cavendish
Country of Publication: UK
Format: Hardback
Price: £125.00
Paperback edition , ISBN13 9780415574587



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Pure economic loss is one of the most-discussed problems in the fields of tort and contract. How do we understand the various differences and similarities between these systems and what is the extent to which there is a common-core of agreement on this question? This book takes a comparative approach to the subject, exploring the principles, policies and rules governing tortious liability for pure economic loss in a number of countries and legal systems across the world.

The countries covered are USA, Canada, Japan, Israel, South Africa, Japan, Romania, Croatia, Denmark and Poland, with the contributors taking a comparative fact-based approach through the use of hypothetical problems to analyze and then summarize the individual country's tort approach.Using a fact-based questionnaire, a tested taxonomy, and a sophisticated comparative law methodology, the authors convincingly demonstrate that there are liberal, pragmatic and conservative regimes throughout the world.

The recoverability of pure economic loss poses a generic question for these legal systems - it is not just a civil law versus common law issue. It will be of interest to students and academics studying tort law and comparative law in the different countries covered.

Subjects:
Comparative Law
Contents:
Preface
Part 1 Introduction
2. The Liability Systems--A functional Ordering
Part 2: The National Contributions
1. Japan
2. Croatia
3. Quebec
4. United States
5. Canada
6. Israel
7. South Africa
8. Poland
9. Denmark
Part 3
1. Surveying the Results
2. General Conclusions