Product Liability in Comparative Perspective

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Cambridge University Press, Oct 27, 2005 - Law - 363 pages
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This 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.
 

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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
Product liability a history of harmonisation
202
Harmonisation or divergence? A comparison of French
221
Product liability law in Central Europe and the true impact
244
Bugs in AngloAmerican products liability
295
from
334
Appendix
341
Index
350
Copyright

Approaches to product liability in the EU and Member
192

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About the author (2005)

Duncan Fairgrieve is Director of the Tort Law Centre at the British Institute of International and Comparative Law, and is also Maître de Conférences at Sciences Po, Paris.

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