وبلاگ منابع حقوقی دکتر احمد بیگی

The purpose of this paper is to delineate new similarities and future differences between

legal systems, using pre-contractual liability and good faith. Instead of focusing on the

differences between common law and civil law, we focus our attention on the gap

between Europe, England included, and United States. All over Europe, under the

influence of good faith jurisprudence, duty to inform has been extremely broadened.

Contemporary debate confirms that European Legal Academia overemphasizes the

importance of the quest for central common principles of European private law, like

Good Faith and

effects of disclosure, parties informational rent seeking and general policy

considerations. A stereotyped legal doctrine, concentrating on the influence of EU

directives on national legal system and, in some cases, unification as a forthcoming

national-positive law can create an undesirable effect in the creation of future case law