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Mixed Legal Systems in Comparative Perspective$
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Reinhard Zimmermann, Kenneth Reid, and Daniel Visser

Print publication date: 2005

Print ISBN-13: 9780199271009

Published to Oxford Scholarship Online: March 2012

DOI: 10.1093/acprof:oso/9780199271009.001.0001

Unjustified Enrichment

Chapter:
(p. 399 ) 14 Unjustified Enrichment
Source:
Mixed Legal Systems in Comparative Perspective
Author(s):

REINHARD ZIMMERMANN

DANIEL VISSER

KENNETH REID

Publisher:
Oxford University Press
DOI:10.1093/acprof:oso/9780199271009.003.0014

The laws of unjustified enrichment in the sister mixed legal systems of South Africa and Scotland resemble each other much more closely than they resemble the law of unjustified enrichment in any other country. This chapter considers how South Africa and Scotland have addressed the following questions: Which hurdles have to be overcome to establish a generalized notion of liability? What opportunities are created by developing such a generalized form of liability? It shows that the new order in each system — based on a principled, generalized approach to enrichment liability — contains within it the power to correct the difficulties that exist in each system. This can, however, be achieved only if there is sufficient willingness on the part of judges to unlock the possibilities inherent in this new approach.

Keywords:   laws of unjustified enrichment, mixed legal system, Scots law, South African law, liability

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