This article considers the essential nature of promise and donation, and examines to what extent donation has been seen as a promissory transaction in the legal systems of Ancient Rome, Louisiana, Scotland, South Africa, France, Germany, England and the US Common Law jurisdictions. It concludes by considering the treatment of donation in the Draft Common Frame of Reference (DCFR).
|Number of pages||33|
|Journal||Tulane European and Civil Law Forum|
|Publication status||Published - 2011|