Modernising Civil Liability Law in Europe, China, Brazil and Russia

Non-contractual liability, stemming from damage accountably caused to another, has been the subject of the PETL and DCFR VI European reform initiatives. Gert Brüggemeier, however, proposes alternative reforms which, instead of trying to overcome the differences between civil law (delict) and common law (torts), are restricted to civil liability. The focus is on the grounds of accountability, and stricter forms of liability are at the fore. Quasi-strict enterprise liability is introduced to fill the lacuna between personal fault and forms of strict liability. A commentary is included on recent legislation on civil liability in China, Brazil and Russia to demonstrate how these large countries try to come to grips with the challenges of risk society.

Spis treści:
1. Draft bill on civil liability law
2. Text
3. Commentary
4. European reform proposals
5. Principles of European Tort Law (PETL)
6. Draft Common Frame of Reference Book VI
7. Recent legislation on civil liability law
8. China
9. Text
10. Commentary
11. Brazil
12. Text
13. Commentary
14. Russia
15. Text
16. Commentary.