Analysis of the Foundations and Conditions of Employer's Civil Liability Arising from Employee's Act in Iranian and English Law by meysam musapour, Abouzar Esmaeli

“…Another form of liability arising from the act of another person is known in common law as "vicarious liability," which is interpreted as proxy liability. …”
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The Urgency of Regulating Injunctions In Indonesian Civil Procedure Bill by I Gusti Ngurah Anom Manacika Mahawijaya, Febrilian Dame Nuraldi, Michael Sebastian Chang

“…The concept of injunction in common law countries is similar to the concept of provision, confiscation, and provisional determination so that the concept of injunction can be used to complete the deficiencies of provision, confiscation, and provisional determination. …”
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Dation in Payment: A comparative Study of Islamic Jurisprudence and French Law by mahmoud Kazemi, Abolfazl Shahin

“…In contrast, there are many discussions in French law and Common Law system in this regard. In the present paper, it is attempted to investigate the condition of realization, legal nature, rules and effects of this institution in Iranian legal system and Islamic jurisprudence through a comparative study with French legal system and Common Law. …”
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Exploring Solutions to the Conflict between the Ownership of Trust Property and the Numerus Clauses by Jin Wanyi, Li Yijia

“…The principle of numerus clauses is the basic principle of civil law countries, and trusts, as a product of the common law system, are bound to diverge from it. Among them, the conflict between the ownership of trust property and the numerus clauses is the most significant. …”
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Transaction Structures in the Developing World: Evidence from Private Equity by Lerner, Josh, Schoar, Antoinette

“…These contractual differences appear to have real consequences: larger transactions with higher valuations are seen in common law countries. These findings suggest that the structure of a country's legal system affects private contracts and cannot easily be undone by (bi-lateral) private solutions.…”
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Transaction Structures in the Developing World: Evidence from Private Equity by Lerner, Josh, Schoar, Antoinette

“…These contractual differences appear to have real consequences: larger transactions with higher valuations are seen in common law countries. These findings suggest that the structure of a country's legal system affects private contracts and cannot easily be undone by (bi-lateral) private solutions.…”
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A critical appraisal of the parol evidence rule in contract law by Shair Mohamed, Mohd. Akram, Ali Mohamed, Ashgar Ali

“…Under the common law the 'hallowed principle' in contract law is that once the parties have reduced their agreement into a written form, in the event of a dispute between them as to the written terms of the contract,they are prohibited from adducing extrinsic evidence to add to, subtract from, vary or contradict the written terms. …”
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The incremental growth of unfair competition law in India by Gangjee, DS

“…<p>• In keeping with other common law jurisdictions, India lacks a unified legal basis for protection against unfair competition. …”

Hak kontraktual pihak ketiga: kerangka praktikal bagi Malaysia by Suzanna Mohamed Isa, Sakina Shaik Ahmad Yusoff

“…Pada awalnya, hak kontraktual pihak ketiga dianggap lazim bagi negara-negara yang mengamalkan undang-undang sivil namun asing bagi negara-negara yang mengamalkan common law. Kini, semakin banyak negara common law yang menyedari ketidakadilan kepada pihak ketiga yang diberi faedah menerusi kontrak oleh pihak-pihak yang berkontrak lalu mereka mengubah kerangka perundangan mereka bagi memberi keadilan kontraktual kepada pihak ketiga. …”
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Justinian in the Hinterlands: Roman Law as an Introduction to a Standard Curricular Course on English Legal History by Michael H Hoffheimer

“…The perception of the common law tradition as insular and autonomous is rooted deeply and efforts to challenge it have been controversial. …”
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Ke arah penerimaan culpa in contrahendo di bawah undang-undang kontrak Malaysia by Mohd Azizie Abdul Aziz, Sakina Shaik Ahmad Yusoff

“…Kengganan untuk berubah ini berpunca daripada keterikatan terhadap tradisi common law Inggeris dan ideologi liberalisme yang mendasari Akta tersebut. …”
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Enforcement e conservadorismo contábil: análise das companhias de capital aberto dos países membros do G20 by Vanessa Noguez Machado, Suliani Rover

“…A partir da análise comparativa dos resultados, foi possível evidenciar que países desenvolvidos tendem a apresentar maior conservadorismo em seus números contábeis, assim como países com sistema legal de Common Law, constatando que um enforcement mais rigoroso tende a fazer com que as empresas apresentem maior conservadorismo em seus resultados. …”
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Dishing up Israel: Rethinking the Potential of Legal Mixité by Susan G. Drummond

“…The paper does not take as a point of inquiry either the classic Civil law/Common law mix of the jurisdiction, nor its increasingly more strident religious law/secular law tension. …”
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Hukum dan Keadilan Sosial dalam Perspektif Hukum Ketatanegaraan by Ahmad Fadlil Sumadi

“…Law is known as the common law or customary law and the second is the religious law, in particular, Islam with its Islamic law. …”
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Efficient Standard of Proof by Iraj Babaei, Shahin Shamiaghdam

“…Lawyers trained in common law systems often enquire about the applicable standard of proof but in civil law countries and particularly Iranian law it depends on the discretion of judges and there are no clear rules. …”
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Statehood experience, legal traditions, and climate change policies by Ang, James Bengjiunn, Fredriksson, Per G.

“…Therefore, the implications of receiving British common law versus French civil law should be particularly important in countries with a greater accumulated history of statehood. …”
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Pertanggungjawaban Produk Dari KUHperdata (Bw) Ice Uu No 8 Tahun 1999 TentangPerlindungan Konnsume by Perpustakaan UGM, i-lib

“…Sekalipun disebut dengan istilah yang sama namun menurut sejarah perkembangannya, strict liability di dalam Civil law system ternyata mempunyai akar yang berbeda dengan strict liability dalam Common law system. Melalui pendekatan historis maupun perbandingan hukum serta metode penemuan hukum kiranya akan diperoleh suatu ikhtisar mengenai konstruksi yuridis strict liability balk dari Civil law maupun Common law system. …”

Dismissal from employment and the remedies by Ali Mohamed, Ashgar Ali

“…Dismissal from employment and the remedies is basically intended to provide a clear understanding that surrounds the concept of a worker's 'security of tenure' in employment with reference to common law and statutory law. It elaborates the remedies of workers at common law wrongful dismissal and statutory unfair dismissal in further bringing to light the concept of 'security of tenure' in employment. …”
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The reception of the law relating to Res Gestae in Malaysia

“…If no, what is the different approach taken by the Malaysian Courts compared to the Common Law principle?…”
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Quantum of proof when case for the prosecution depends substantially or wholly on circumstantial evidence: irresistible conclusion test or reasonable beyond a doubt test? by Shair Mohamad, Mohd Akram

“…Some insights from the Islamic law position on circumstantial evidence are also examined with a view to resolving the lingering conflict of opinions among the common law jurisdictions. …”
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