Product Liability in Comparative PerspectiveThis book examines the law of product liability from a comparative perspective. With the European Directive on Product Liability enacted over 20 years ago, this publication analyses the state of product liability in a number of key jurisdictions including both Western European countries and New Member States. Account is also taken of developments further afield, including the United States and Japan. Distinguished contributors, including a high court judge, European Commission official, leading litigators and academics, provide individual country reports and a number of integrated comparative studies. The book is designed for practical use by legal practitioners, academics, students and others interested in the area of contract, tort, civil procedure and multi-party litigation. In particular, practitioners will find the country reports an essential reference point. |
Contents
The use of comparative law in A Others v National Blood | 13 |
Spanish product liability today adapting to | 42 |
Interaction between the European Directive on Product | 67 |
liability | 84 |
between European Directives | 100 |
Dutch case law on the EU Product Liability Directive | 126 |
basic problems in a comparative | 155 |
The development risks defence | 167 |
Approaches to product liability in the EU and Member | 192 |
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Common terms and phrases
action apply Article 13 Article 7(e blood products bottle Burton Cass causal Central Europe Central European Civil Code claimant claims comparative law compensation consumer protection Consumer Protection Act contract Cour de Cassation Court of Justice Czech Czech Republic damage caused decision defective products design defects development risks defence English entitled to expect European Commission European Court European Product Liability European Union existence fact fault footnote GERAINT HOWELLS German harmonisation Hepatitis Hungarian Hungarian Product Liability Hungary Ibid implementation infection interpretation issue judge judgment legislation liability for defective liability system litigation LRPD manufacturing defects Member National Blood Authority negligence obligation de sécurité Product Liability Act Product Liability Directive product liability law product liability regimes product safety provisions put into circulation reasonable reference reform regulation relevant responsabilidad civil Restatement Third seller standard strict liability supplier Supreme Court thalidomide tort law United Kingdom victim warn