This chapter explores the law of agency in relation to European contract law. It explains that agency is often considered to be more properly part of commercial rather than contract law and evaluates the extent of English influence which has operated on contract law in Scotland and South Africa. The chapter discusses the innovations in English law contained within the Principles of European Contract Law (PECL), and how useful those might be for Scots and South African lawyers. It argues that the PECL framework for indirect representation and apparent authority is likely to be acceptable to Scots and South African lawyers, and that it is clear that the Common Law has been highly influential in the modelling of the PECL provisions.
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