This major reference work compares the formation of contract in the legal systems of England, France, Iran and other Islamic systems. The Preliminary Part gives a historical sketch and describes the sources of law of the four legal systems. It then describes the development and general theory of contract law in the four systems. Part One then analyses in detail the basic notions of formation of contract including the range of psychological elements and their means of expression. The author then goes on to describe and compare the function and determination of offer and acceptance in the four legal systems. Part Two analyses the mechanism of formation and import of a contract in respect of both offer and acceptance. The book has been extensively researched and includes references to Roman law and other modern legal systems. The work has been meticulously indexed and cross-referenced.

The book analyzes the most relevant developments in the relation between contracts and technology, from automatically concluded contracts to today's revolutionary "smart contracts" developed through blockchain, which are beginning to and will increasingly disrupt many economic and social relations. First of all, the author offers a broad analysis of the peculiarities and evolution of the relation between contracts and technology. The main features and elements of electronic contracts are then examined in depth to highlight the specific rules applicable to them in the international comparative legal framework. In turn, the book provides a detailed explanation of the technology, economic and social dynamics, and legal issues concerning blockchain and smart contracts. The analysis focuses on the question of the legal nature of smart contracts, the issues posed by their development and the first legal solutions adopted in some countries. The comparative approach pursued makes it possible to focus attention on the first solutions adopted until now in various systems, with particular regard to the circulation of models and ideas and to the specificities of their local variations, in terms of e.g. applicable law and jurisdiction. In reviewing the characteristics of distributed ledger technologies, and in particular of the blockchain technology on which smart contracts are based, above all the peculiarities of the latter are taken into consideration, especially automatic execution and resistance to tampering, which simultaneously present significant opportunities and complex legal issues. A comprehensive framework is then provided to reconcile smart contracts with comparative contract law, in order to define the scope and specificities of their binding force, legal effectiveness and regulation in various legal systems. Lastly, with specific reference to the elements, pathologies and contractual remedies for smart contracts, the book examines the peculiarities of their application and the main issues that emerge in comparative contract law in order to promote their harmonized use, in keeping with the transnational nature of such a revolutionary tool.