The English common law and French civil code : a dialogic analysis of private law and interpretational variances : special study on the law of contract and tort

Abstract EN

For some, English law has, since the dawn of colonialism, been a popular choice for commercial transactions in part because it is considered sufficiently certain in many respects.

Yet, for others, the French Civil Code represents codified objectivity that the common law lacks.

For many, however, given the advent of globalization, it is beyond semantics.

What is more, there is more than a trace of convergence between the two in areas of contract and tort law.

This paper pays tribute to the body of laws that have informed and enriched international commerce.

Specifically, the value of this paper is its identification of an emerging convergence between the common law and the French civil code both of which dominate global trade in subtle but palpable nuances.