Common Law and Civil Law Perspectives on Tort Law

The book provides a comparative overview of the law of civil liability for injuries arising outside of contract in five major legal systems in the common law and civil law traditions: England, the United States, France, Germany, and Italy. By analysing a select number of foundational issues that lie at the core of tort law in all the jurisdictions surveyed, the book provides an updated and enriched framework for understanding the rules, the theories, the styles of reasoning and the tort law cultures across the Atlantic.