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Various countries have reformed their secured transaction laws recognizing the significance of modern secured transactions law in enhancing access to credit and economic development. Ethiopia has not undertaken comprehensive secured transactions law reform, despite the demonstrable mismatch between the legal regime governing security interests and the ...
Asress Adimi Gikay
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Comparative Interpretation Standards in Uniform International Law [PDF]
In this chapter, the author offers a horizontal comparison of interpretation standards contained in international legal instruments of different origin. These legal instruments range from international treaties to model laws. They also originate from different law makers such as the United Nations or individual states as well as trade or academic ...
Maren Heidemann
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Sixteen West African, mostly francophone countries have entered into a treaty pursuant to which they have adopted uniform business laws. The treaty also provides a mechanism for adopting new uniform business laws and modifying existing ones, and for a single judicial interpretation of these laws across the treaty territory.
Claire Dickerson
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Promoting Uniformity: A Comparative Review of J Honnold and H Flechtner, Uniform Law for International Sales under the 1980 United Nations Convention and P Schlechtriem and I Schwenzer, Commentary on the UN Convention on the International Sale of Goods [PDF]
Academic commentaries on the United Nations Convention on Contracts for the International Sale of Goods (hereafter CISG) arguably perform a more important role than most legal academic texts. That role is essentially to assist in an international, uniform interpretation of the CISG. This becomes important because the CISG is an international convention
Therese Wilson
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THIS article compares the provisions of the UN Convention on Contracts for the International Sale of Goods (Vienna, 1980--"the UN Sales Convention")' to those of the Uniform Law on the International Sale of Goods (ULIS) and the Uniform Law on the Formation of Contracts of Sale (ULF) (Hague Conventions, 1964).2 The ULIS and the ULF served as the ...
Muna Ndulo
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In Africa, two organizations have developedsupranational legal frameworksapplyingto cooperative societies. The first isthe Organization for the Harmonization of Business Law in Africa, in French Organisation pour l’harmonisation en Afriquedu droit des affaires(OHADA)with the Uniform Act onCooperative Societies(UA).
Willy Tadjudje
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The Uniform Model of the Business-Judgment Rule: a Comparative Study in English, American, Australian and Iranian Law [PDF]
The Business-Judgment Rule can be defined as a doctrine that protects directors from personal responsibilities if they act in good faith, with due care and within the framework of their powers and duties, including the care and fiduciary duty ...
hamid Abhary +2 more
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Our article is based on a fresh dialogue between two colleagues of public international law and comparative private law. We question whether the standard of interpretation of uniform private conventions is, or should be, identified and shaped under the two scholarships. In particular, we aim to answer three main research questions.
Lorenza Mola, Cristina Poncibò
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"The Bermuda triangle" of company, bankruptcy and law on takeover of joint stock companies: Three subjects of protection: Company, creditor and shareholder [PDF]
Company, bankruptcy and the law on takeover of joint stock companies, by regulating the duties (obligations - debtor of the obligation) of members of the management of the public joint stock company (first of all), do not have the same approach in ...
Vasiljević Mirko S.
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