The United Nations Convention on Contracts for the International Sale of Goods (CISG), adopted in April 11, 1980, is an attempt to unify rules of international trade. A large number of states that represent a variety of legal systems and of degrees of development have adhered to this Convention. / As a result of the divergence of approaches and rules in these systems, several issues were debated during the negotiations, among others the remedy of specific performance. / This thesis examines the provisions regarding specific performance in the Convention in attempt to reveal the divergence of approaches between Common Law and Civil Law by means of a comparative study of the two systems. / The purpose is to assess the extent to which uniformity is achieved in the Convention. The study shows that the solution adopted regarding specific performance was a compromise that threatens uniformity to a certain degree.
Identifer | oai:union.ndltd.org:LACETR/oai:collectionscanada.gc.ca:QMM.30286 |
Date | January 1999 |
Creators | Boghossian, Nayiri. |
Contributors | Jutras, Daniel (advisor) |
Publisher | McGill University |
Source Sets | Library and Archives Canada ETDs Repository / Centre d'archives des thèses électroniques de Bibliothèque et Archives Canada |
Language | English |
Detected Language | English |
Type | Electronic Thesis or Dissertation |
Format | application/pdf |
Coverage | Master of Laws (Institute of Comparative Law.) |
Rights | All items in eScholarship@McGill are protected by copyright with all rights reserved unless otherwise indicated. |
Relation | alephsysno: 001740906, proquestno: MQ64262, Theses scanned by UMI/ProQuest. |
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