For some Western European legal systems the principle of good faith has proved central to the development of their law of contracts, while in others it has been marginalized or even rejected. This book starts by surveying the use or neglect of good faith in these legal systems and explaining its historical origins. The central part of the book takes thirty situations which would, in some legal systems, attract the application of good faith, analyses them according to fifteen national legal systems and assesses the practical significance of both the principle of good faith and its relationship to other contractual and non-contractual doctrines and forms of regulation in each situation. The book concludes by explaining how European lawyers, whether from a civil or common law background, may need to come to terms with the principle of good faith. This was the first completed project of The Common Core of European Private Law launched at the University of Trento.

How could the Right transform itself from a politics of the nobility to a fatally attractive option for people from all parts of society? How could the Nazis gain a good third of the votes in free elections and remain popular far into their rule? A number of studies from the 1960s have dealt with the issue, in particular the works by George Mosse and Fritz Stern. Their central arguments are still challenging, but a large number of more specific studies allow today for a much more complex argument, which also takes account of changes in our understanding of German history in general. This book shows that between 1800 and 1945 the fundamentalist desire for a single communal faith played a crucial role in the radicalization of Germany's political Right. A nationalist faith could gain wider appeal, because people were searching for a sense of identity and belonging, a mental map for the modern world and metaphysical security.

A unique comparative analysis of Chinese contract law accessible to lawyers from civil, common, and mixed law jurisdictions.

Decades after the Holocaust, many assume that the churches in Germany resisted the Nazi regime. In fact, resistance was exceptional. The Deutsche Christen, or "German Christians," a movement within German Protestantism, integrated Nazi ideology, nationalism, and Christian faith. Marrying religious anti-Judaism to the Nazis' racial antisemitism, they aimed to remove everything Jewish from Christianity. For the first time in English, Mary M. Solberg presents a selection of "German Christian" documents. Her introduction sets the historical context. Includes responses critical of the German Christians by Karl Barth and Dietrich Bonhoeffer.

In force in 70 countries around the world and covering more than two thirds of world trade, the 1980 United Nations Convention on Contracts for the International Sale of Goods (CISG) is considered to be the most successful convention promoting international trade. According to many commentators, this success is due, among others, to the fact that the Convention does not directly impact on the domestic law of the various legal systems, as it applies only to international - as opposed to purely domestic - contracts. The Convention, in other words, does not impose changes in the domestic law, which makes it easier for States to adopt the Convention. This does not mean, however, that the Convention does not have any impact on the domestic law at all. This book analyzes - through 24 country reports as well as a general report submitted to the 1st Intermediate Congress of the International Academy of Comparative Law held in November 2008 in Mexico City - to what extent the Convention de facto influences domestic legal systems. In particular, the book examines the Convention's impact on the practice of law, the style of court decisions as well as the domestic legislation in the area of contract law.