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Mistake and Non-Disclosure of FactsModels for English Contract Law$
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Hugh Beale QC FBA

Print publication date: 2012

Print ISBN-13: 9780199593880

Published to Oxford Scholarship Online: September 2012

DOI: 10.1093/acprof:oso/9780199593880.001.0001

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Mistake and Non-Disclosure in Other Systems

Mistake and Non-Disclosure in Other Systems

Chapter:
(p.33) 2 Mistake and Non-Disclosure in Other Systems
Source:
Mistake and Non-Disclosure of Facts
Author(s):

Hugh Beale

Publisher:
Oxford University Press
DOI:10.1093/acprof:oso/9780199593880.003.0002

This chapter examines a selection of other laws of contract, particularly models found in national systems that supposedly form the basis of the PECL provisions. It first studies the Commonwealth laws, where it identifies two cases that have deviated from the doctrine of unconscionability. The next section deals with European models, specifically Dutch, French, Scandinavian, and German laws. The laws of individual states in the U.S. are discussed in the final part of the chapter.

Keywords:   laws of contract, national systems, PECL provisions, commonwealth laws, doctrine of unconscionability, European models, laws of individual states

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