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A Comparative Analysis of the Standard of Fraud Required Under the Fraud Rule in Letter of Credit Law
Fraud Rule Fraud Required
2015/8/4
The fraud rule allows the issuer of a letter of credit or a court to disrupt the payment of a letter of credit when fraud is involved. The raison d’etre of letters of credit is to provide an absolute ...
The discipline ‘comparative law’ seems still to be distinguishing itself from lawmaking. In this paper I investigate theoretical reasons for this and propose a new type of concept of law, which should...
The present paper seeks to give a comparative overview of restitution for wrongs in three legal systems which deal with that institution from quite different perspectives. The terms "restitution for w...
Dignity - The Enemy from Within: A Theoretical and Comparative Analysis of Human Dignity as a Free Speech Justification
Theoretical and Comparative Analysis Enemy
2015/8/4
This Article challenges the use of human dignity as an independent free speech justification. The articulation of free speech in human dignity terms carries unwarranted potential consequences that may...
The Role of Reasonable and Unreasonable Mistake in Justified Defences A Comparative and Analytical Study
Justified Defences Analytical Study
2015/8/4
Justified defence negates the wrongful character of conduct that falls within the definition of an offence. Conduct performed under conditions of a justified defence does not constitute an offence. Fo...
The Adjudication of the German Federal Supreme Court (BGH) in the Last 55 Years - A Quantitative and Comparative Approach
German Federal Supreme Court Comparative Approach
2015/8/4
Today, many law journals can be accessed electronically. This is not only convenient but it also offers the interesting possibility of a quantitative analysis. In the US, this is already quite common,...
Comparative advertising has been widely used for over thirty years in the United States. By contrast, the use of this advertising format has traditionally been – and still is – very marginal in France...
Society's Most Vulnerable Under Surveillance: The Ethics of Tagging and Tracking Dementia Patients With GPS Technology: A Comparative View
Tagging and Tracking Dementia Patients Surveillance
2015/8/4
The twentieth century was marked by an explosion of human rights, what Irwin Cotler eloquently deems the "secular religion of our times"4. Endeavouring to protect society's most vulnerable – children,...
A Note on Comparative Family Law: Problems, Perspectives, Issues and Politics
Problems Perspectives Issues Politics
2015/8/4
Many comparatists view family law as an impenetrable and unproductive field of legal policy. This perspective invariably draws on Montesquieu and the argument that there are particularly close ties be...
A Microcosm of Comparative Law: the Overlay of Customary, French and English Family Law in Present Day Vanuatu
Overlay of Customary French
2015/8/4
The Pacific republic of Vanuatu is an archipelago of islands located off the East coast of Queensland, Australia, at 16 00 S and 167 00 E. To most people it is a speck on the map (Fig. 1). However, Va...
Systems Dynamics in the Law: A Comparative Approach to Certainty in the Common Law and Reviewability of Past Decisions
Law Systems Dynamics
2015/8/4
The present paper takes a fresh look at the issues of certainty of law and the problem of reviewability of past decisions. The author draws on experience in teaching law to students from exact science...
Towards a Social Value Convergence: a Comparative Study of Fundamental Principles of Contract Law in the EU an
Social Value Convergence Fundamental Principles
2015/8/4
One of the remarkable differences in contract law between legal systems in the European Union and China is the definition and status of contractual freedom. Historically, contractual freedom has not b...
美国比较法协会（American Society of Comparative Law，ASCL）
美国比较法协会 American Society of Comparative Law ASCL）
2015/8/3
The American Society of Comparative Law, Inc. (ASCL) is the leading organization in the United States promoting the comparative study of law. Founded in 1951, it is a thriving organization of more tha...
密西根大学国际法和比较法研究中心（The Center for International and Comparative）
密西根大学国际法和比较法研究中心 The Center for International and Comparative legal education
2015/8/3
UB School of Law faculty, staff and administration are honored to contribute to the transformative experience of an education in the law.At the University of Baltimore School of Law, you will learn do...
Un établissement autonome de la Confédération Suisse, rattaché au Département fédéral justice et police, ouvert au public depuis 1982.