False Friends in Comparative Law
Advantages and Risks of Legal Transplants in Civil Law – the Polish-German Perspective
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Beschreibung
Comparative Analyses of Legal Transplants – the Polish-German Perspective
German law served as an inspiration for Polish legislators in the 20th century and continues to influence the Polish legal scholarship, jurisprudence and legal practice. This influence is visible also in Polish civil law. The aim of the book was to collect outcomes of research analysis of concepts and theories of Polish civil law which appeared to be examples of legal transplants from German law, and to determine their actual nature. The individual chapters of the book focus on specific concepts and theories of civil law. In the outcomes of comparative analysis the authors point out both the advantages and the risks of legal transplants, as well as distinguish between genuine and false transplants from German to Polish civil law.
Autor*in
Przemysław Drapała
Przemysław Drapała – Dr hab., is Associate Professor at Kozminski University, Poland, and member of the Expert Working Groups of the Civil Law Codification Commission, the ICC Poland, and the German Arbitration Institute.
Themen in »False Friends in Comparative Law«
Civil Law Poland Legal Transplants False Friends Comparative Law Obligation Law German Law