Concordance of Contract Law of China, EU, USA and Russia
A developed law of contract is the foundation of commerce in most developed economies. The growth and interdependence of transnational commerce has led to an increasing concern with the harmonisation of apparently very diverse legal traditions. Our work on drafting the ACC led us to form the hypothesis that rules stated at the level of generality of its Articles were likely to be part of contract law of most legal systems. We are currently testing this hypothesis by a detailed comparison of the common law of contract, as applied by Australian courts, with the contract law of China, the EU, the USA, and Russia. For this purpose we have created a Concordance of four major contract codes. They are:
- Restatement (Second) of Contracts (USA)
- Principles of European Contract Law (EU)
- Contract Law of the People's Republic of China
- Civil Code of the Russian Federation
Download Concordance project document (PDF, 1100KB)