The CISG and the United Kingdom: Exploring Coherency and Private International Law

International and Comparative Law Quarterly, Vol. 67, No 3, 2018

Posted: 3 Aug 2018

See all articles by Benjamin Hayward

Benjamin Hayward

Monash University - Department of Business Law & Taxation

Bruno Zeller

University of Western Australia - Faculty of Law

Camilla Baasch Andersen

The University of Western Australia Law School

Date Written: 2018

Abstract

The United Kingdom remains one of the world's last industrialized nations not to have adopted the CISG. The UK CISG debate has endured for decades, with existing analysis largely focusing on competition, assessing the relative merits of the CISG and English law. This article's analysis is complementary; focusing instead on coherence, and the private international law implications of UK accession. This article assesses contractual interpretation, and commodity sales, within an overarching private international law framework. Recognizing the necessity of existing competitive analyses, it makes the case for UK CISG accession on the basis of its complementary coherency perspective.

Suggested Citation

Hayward, Benjamin and Zeller, Bruno and Andersen, Camilla Baasch, The CISG and the United Kingdom: Exploring Coherency and Private International Law (2018). International and Comparative Law Quarterly, Vol. 67, No 3, 2018, Available at SSRN: https://ssrn.com/abstract=3214275

Benjamin Hayward (Contact Author)

Monash University - Department of Business Law & Taxation ( email )

Caulfield Campus
Sir John Monash Drive
Caulfield East, Victoria 3084
Australia

Bruno Zeller

University of Western Australia - Faculty of Law ( email )

M253
35 Stirling Highway
Crawley, Western Australia 6009
Australia

Camilla Baasch Andersen

The University of Western Australia Law School ( email )

M253
35 Stirling Highway
Crawley, Western Australia 6009
Australia

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