This research paper shall examine from a comparative perspective the regime of product liability in Anglophone Cameroon and South Africa. It begins with an overview of product liability and illustrates on the concept. It further highlights the contractual and delictual basis for liability as well as the evolution of the no-fault liability regime and the extent of its application across jurisdictions. Chapter one shall discuss product liability in the English Speaking region of Cameroon where negligence is predominantly used as the basis for liability. Chapter two shall also examine product liability under the Republic of South Africa, where under the current legislation liability is still based on negligence. However a comparative study will be drawn from the test of determination of negligence which differs under Anglophone Cameroon and South Africa. Though at present South Africa utilizes negligence as a basis for liability, a new legislation has been promulgated into law which introduces the no-fault liability regime as the basis for liability as from April 1st 2011. Chapter three shall critically examine the no-fault liability regime or strict liability under Act 68 of 2008,
This book deals with incorporation, interpretation and validity of liability disclaimers (LD) in unilaterally drafted B2B-standard terms in DK (civil law), England (common law) and United States of America (mostly common law). I mainly analyze the remedy of damages. Other clauses may in reality function as LDs, why the same judicial methods, as a main rule, apply in regards to these clauses also. All three countries have similar approaches, however there are differences a lawyer should be aware about when drafting contracts in these countries and also on how a lawyer should deal with these clauses in matters of dispute.
The purpose of this book is to present the Historical overview on Limitation of Liability; The 1976 Limitation Convention as amended by the 1996 Protocol; The CMI Guidelines 2008 and the European Union Legislation (DIRECTIVE 2009/20/EC OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 23 April 2009 on the insurance of shipowners for maritime claims) in this context. The book explains the existing provisions of the Bulgarian Merchant Shipping Code in relation to Limitation of liability and the Law for ratification of the International Convention on Limitation of Liability for Maritime Claims (LLMC, 1976) as amended by the Protocol of 1996.
Accessory liability is an often neglected but very important topic across all areas of private law. By providing a principled analytical framework for the law of accessories and identifying common themes and problems that arise in the law, this book provides much-needed clarity. It explains the fundamental concepts that are used to impose liability on accessories, particularly the conduct and mental elements of liability: 'involvement' in the primary wrong and (generally) knowledge. It also sets out in detail the specific rules and principles of liability as these operate in different areas of common law, equity and statute. A comparative study across common law and criminal law jurisdictions, including the United States, also sheds new light on what is and what is not accessory liability.
The Law of Primitive Man – A Study in Comparative Legal Dynamics
Vietnam & the Chinese Model – A Comparative Study of Nguyen & Ching
The Book “ MODERNITY IN PERSIAN AND ASSAMESE POETRY WITH SPECIAL REFERENCE TO IRAJ MIRZA, MOHD. TAQI BAHAR, NAVA KANTA BARUA & NILAMONI PHUKAN – A COMPARATIVE STUDY” is regarded as useful reference Book for Studying the modernization of persian and Assamese poetry. It Consists of six important Chapter dealing with Modernism, Modernization of persian poetry, Modernization of Assamese poetry, Modernity in the poetry of Md. Taqi Bahar and Iraj Mirza, Modernity in the poetry Navakanta Barua and Nilamoni Phukan, Modernity in Persian and Assamese poetry – A comparative study
Drawing upon the author’s three decades of work in comparative theology, this is a pertinent and comprehensive introduction to the field, which offers a clear guide to the reader, enabling them to engage in comparative study. The author has three decades of experience of work in the field of comparative theology and is ideally placed to write this book Today’s increasing religious diversity makes this a pertinent and timely publication Unique in the depth of its introduction and explanation of the discipline of ‘comparative theology’ Provides examples of how comparative theology works in the new global context of human religiosity Draws on examples specific to Hindu-Christian studies to show how it is possible to understand more deeply the wider diversity around us. Clearly guides the reader, enabling them to engage in comparative study
Moral Struggle and Religious Ethics offers a comparative discussion of the challenges of living a moral religious life. This is illustrated with a study of two key thinkers, Bonaventure and Buddhaghosa, who influenced the development of moral thinking in Christianity and Buddhism respectively. Provides an important and original contribution to the comparative study and practice of religious ethics Moves away from a comparison of theories by discussing the shared human problem of moral weakness Offers an fresh approach with a comparison of the understanding of the problem of moral weakness between the two key thinkers, Bonaventure and Buddhaghosa Written by a highly respected academic in the dynamic and fast-growing field of comparative religious ethics
Premodern Financial Systems: A Historical Comparative Study describes (in quantitative terms whenever possible) the financial superstructure, such as the method of financing the government, and links it to the essential characteristics of the infrastructure of nearly a dozen societies ranging from Athens in the late fifth century BC to the United Provinces in the mid-seventeenth century.
Construction industry is one of the accelerations for the National economy.However, there are numerous problems exist in the collaborative relationship under the construction process. This paper takes a qualitative approach on a comparative study of collaborative relationship in the construction industry of Mongolia pre- vs. post- institutional transition in 1990. We find that in the pre-transition, collaborative relationship was authority based because of homogenous participant background,command entry barrier,formal decision law on conflict resolution, high sense of liability, rare price adjustment, whereas, in the post-transition, collaborative relationship is trust based or opportunism driven depending on whether long-term partnership and free market competition because of heterogeneous participant background, market entry barrier, economic interest on conflict resolution, divergence of interests causing agency problem, low sense of liability, and flexible price adjustment.
Taking the account of linguistics research based on comparative studies, the languages spoken in the Indian sub- continent have been explored rigorously with specific purpose and orientation. While as one admits the fact that the languages spoken in the belt of Jammu and Kashmir state have been touched to a little margin within comparative frame work. In the light of this fact a need was felt to initiate the hitherto unexplored study across these languages / dialects within comparative framework. The present study attempts to take comparative study of word formation of Kashmiri and Kohistani because of the following reasons: 1) Kohistani is one of the dialects of Dard (Grierson), However, the study remained unexplored on modern comparative model. 2) The study paves the way for further studies of Kashmiri- Kohistani that may help in resolving the academically controversial issues on purely scientific lines regarding the dialect status of Kohistani vis-a-vis Kashmiri language. 3) The present study is an attempt to compare morphology of the languages, so as to find out the possible linguistic affinities between Kohistani and Kashmiri.