Towards a Model Sales Law in the Greater Bay Area A Comparative Study of Contract Law in Mainland China, Hong Kong and Macau
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Edited by Hao Jiang, Assistant Professor of Comparative Private Law, Department of Legal Studies, Bocconi University, Italy<i>‘The publication of </i>Towards a Model Sales Law in the Greater Bay Area<i> is most timely. Studies in intra-Asian comparative law, not least in the area of contracts, have met with increasing interest over the past decade. The comparison in the present volume is particularly attractive because of the unusual scenario of “one country, three systems”. Comparing a common law system, a system from the civil law tradition and the unusual, multifaceted system of the PRC in a single volume promises exciting discoveries.’</i>
- Stefan Vogenauer, Max Planck Institute for Legal History and Legal Theory, Germany,
Hao Jiang brings together expert contributors, both from within the region itself and outside of it, to conduct a systematic doctrinal analysis of the region’s contract and sales law. Contributing authors assess legal transplants specifically tracing the influence of German civil law on China along with English common law and Portuguese civil law on Hong Kong and Macau. Chapters cover key doctrinal topics where the three laws converge and diverge including contract formation, pre-contractual liability, vitiating factors, good faith, change of circumstances, and remedies. Ultimately, the book highlights how a unified contract and sales law could facilitate cross-border transactions in the region, and lays the foundations for future empirical research on this subject.
Providing a comparative study of Chinese, Hong Kong and Macau contract law through the lens of European law, Towards a Model Sales Law in the Greater Bay Area is an essential resource for scholars, students and practitioners of private, sales and contract law.