Model EU and Pattern OHADA?
Perspectives of a Mutual Influence in Commercial Law
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Beschreibung
The European Union (EU) and the Organisation pourl'harmonisation en Afrique du droit des affaires (OHADA) are the two most integrated supranational organisations in the world. The contributions in this volume compare the institutional frameworks of both organisations and the results achieved in terms of legal harmonisation and unification.
This volume contains all the papers presented during the working session of the Section for Comparative Commercial and Business Law at the 39th Conference of the German Society for Comparative Law in Berlin. Today, the European Union (EU) and the Organisation pour l'harmonisation en Afrique du droit des affaires (OHADA) are the two most integrated supranational organisations in the world. On the one hand, OHADA was institutionally modelled on the EU. But on the other hand, based on an essentially French legal tradition, OHADA was able to go much further in the unification of commercial law, as evidenced by meanwhile eleven Uniform Acts relating to principally all aspects of commercial law. 140 years after the beginning of the so-called Berlin Conference concerning the Scramble for Africa this comparative approach also reflects the paradigm shift in the relationship between Europe and Africa.
Autor*in
Peter Jung
is Professor of Private Law at the University of Basel.
Themen in »Model EU and Pattern OHADA?«
African business law comparative law European business law European Union Integration International law International legal order law harmonization legal cultures legal harmonization legal methodology legal systems modeling OHADA supranational organizations