Document Type

Article

Publication Title

Loyola of Los Angeles International and Comparative Law Review

Abstract

The purpose of this Article is to outline the laws of torts as it varies with each country's legal system in order to illustrate that the actual differences between the systems are not too relevant. Indeed, generally, "where a plaintiff would recover in France, he would recover, too, in England." Apart from some unique rules, for example punitive damages in common law, compensation for wrongful death of a cohabitating partner in some French based systems, and compensation in kind in some German based systems, the tort law of the various countries tends to produce the same consequences. This affirmation presupposes common aims and common conditions. However, since the conditions for tortious liability are basically the same, there is no doubt that the different law of torts will continue to achieve the very same results.

First Page

813

Volume

15

Publication Date

1993

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