Research output: Chapter in Book/Report/Conference proceedingChapter (peer-reviewed)peer-review

Abstract / Description of output

This chapter explores the law of agency in relation to European contract law. It explains that agency is often considered to be more properly part of commercial rather than contract law and evaluates the extent of English influence which has operated on contract law in Scotland and South Africa. The chapter discusses the innovations in English law contained within the Principles of European Contract Law (PECL), and how useful those might be for Scots and South African lawyers. It argues that the PECL framework for indirect representation and apparent authority is likely to be acceptable to Scots and South African lawyers, and that it is clear that the Common Law has been highly influential in the modelling of the PECL provisions.
Original languageEnglish
Title of host publicationEuropean Contract Law
Subtitle of host publicationScots and South African Perspectives
EditorsHector MacQueen, Reinhard Zimmermann
Place of PublicationEdinburgh
PublisherEdinburgh University Press
Number of pages28
ISBN (Electronic)9780748626489
ISBN (Print)0748624252, 9780748624256
Publication statusPublished - 2006

Publication series

NameEdinburgh Studies in Law


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