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La Validitè Des Contrats En Droit International Privè.

La Validitè Des Contrats En Droit International Privè. 1993] BOOK REVIEW 345 TH E CONFLICTS "REVOLUTION" REVISITED L A VALIDITE DES CONTRATS EN DROIT INTERNATIONAL PRIVE (The Validity of Contracts in Private International Law). By Claude Ferry. Paris: L.G.D.J., 1989. Pp. 354 (in French). Reviewed by Louis Vogel* This book is based on a French doctoral dissertation. It argues tha t th e diverse systems of private international law converge, in the area of international contracts, to satisfy the essential requirement of "favor validatis;" that is, that the various legal systems seek to preserve the validity of the terms of international contracts. In investigating how and to what extent the American and French legal systems satisfy this imperative, Professor Ferry pro­ vides a compilation of the methodologies applied in the United States and France. The work has implications beyond the area of private international law. From a comparative law standpoint, the most interesting aspect involves the administration of justice, and th e so-called "conflicts revolution." 1. First, there is no escaping the fact that implacable abstract rules (e.g., the doctrine of locus regit actum), because ill-suited to th e resolution of specific cases, are increasingly at odds with the needs of contemporary society. From this viewpoint, th http://www.deepdyve.com/assets/images/DeepDyve-Logo-lg.png American Journal of Comparative Law Oxford University Press

La Validitè Des Contrats En Droit International Privè.

American Journal of Comparative Law , Volume 41 (2) – Apr 1, 1993

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Publisher
Oxford University Press
Copyright
© 1993 by The American Society of Comparative Law, Inc.
ISSN
0002-919X
eISSN
2326-9197
DOI
10.2307/840722
Publisher site
See Article on Publisher Site

Abstract

1993] BOOK REVIEW 345 TH E CONFLICTS "REVOLUTION" REVISITED L A VALIDITE DES CONTRATS EN DROIT INTERNATIONAL PRIVE (The Validity of Contracts in Private International Law). By Claude Ferry. Paris: L.G.D.J., 1989. Pp. 354 (in French). Reviewed by Louis Vogel* This book is based on a French doctoral dissertation. It argues tha t th e diverse systems of private international law converge, in the area of international contracts, to satisfy the essential requirement of "favor validatis;" that is, that the various legal systems seek to preserve the validity of the terms of international contracts. In investigating how and to what extent the American and French legal systems satisfy this imperative, Professor Ferry pro­ vides a compilation of the methodologies applied in the United States and France. The work has implications beyond the area of private international law. From a comparative law standpoint, the most interesting aspect involves the administration of justice, and th e so-called "conflicts revolution." 1. First, there is no escaping the fact that implacable abstract rules (e.g., the doctrine of locus regit actum), because ill-suited to th e resolution of specific cases, are increasingly at odds with the needs of contemporary society. From this viewpoint, th

Journal

American Journal of Comparative LawOxford University Press

Published: Apr 1, 1993

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