English common law versus German <em>Systemdenken?</em><br>Internal versus external approaches
This article compares the 'systematic method' of continental German private law with the common law method. It starts out by discussing the characteristics of a systematic approach, its application to European private law as well as its methodological tools. The author submits that the sys...
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| Format: | Article |
| Language: | English |
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Utrecht University School of Law
2011-01-01
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| Series: | Utrecht Law Review |
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| Online Access: | http://www.utrechtlawreview.org/articles/10.18352/ulr.150/ |