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European Contract LawScots and South African Perspectives$
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Hector MacQueen and Reinhard Zimmermann

Print publication date: 2006

Print ISBN-13: 9780748624256

Published to Edinburgh Scholarship Online: March 2012

DOI: 10.3366/edinburgh/9780748624256.001.0001

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PRINTED FROM EDINBURGH SCHOLARSHIP ONLINE (www.edinburgh.universitypressscholarship.com). (c) Copyright Edinburgh University Press, 2020. All Rights Reserved. An individual user may print out a PDF of a single chapter of a monograph in ESO for personal use.date: 31 March 2020

Interpretation

Interpretation

Chapter:
(p.176) 7 Interpretation
Source:
European Contract Law
Author(s):

Eric Clive

Publisher:
Edinburgh University Press
DOI:10.3366/edinburgh/9780748624256.003.0007

This chapter evaluates whether the Principles of European Contract Law (PECL) are predominantly civil law, predominantly common law, or mixed. It considers the PECL rules on interpretation from this point of view and examines whether they are acceptable, and how they compare with the rules in Scots and South African law. The chapter specifically provides an interpretation of the PECL rules in Articles 5:101 and 5:102.

Keywords:   PECL, civil law, common law, rules on interpretation, Scots law, South African law

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