Comparative Foundations of a European La of Set-Off and Prescription [Hardcover]

A comparative 2002 study of the European law of obligations, with a map for a common European approach.The emergence of a European private law is a key legal issue today. Set-off and 'extinctive' prescription are neglected topics in comparative literature. Professor Zimmermann maps out a model for a common European approach, providing practical examples of the arguments that may be employed in the process of harmonising European private law. This volume will interest comparative lawyers and legal historians. These essays originated during his work with the Commission on European Contract Law (the 'Lando-Commission'), whose task is the 'restatement' of European contract law.The emergence of a European private law is a key legal issue today. Set-off and 'extinctive' prescription are neglected topics in comparative literature. Professor Zimmermann maps out a model for a common European approach, providing practical examples of the arguments that may be employed in the process of harmonising European private law. This volume will interest comparative lawyers and legal historians. These essays originated during his work with the Commission on European Contract Law (the 'Lando-Commission'), whose task is the 'restatement' of European contract law.The emergence of a European private law is a key legal issue today. Set-off and extinctive prescription are neglected topics in comparative literature. Reinhard Zimmermann maps out a model for a common European approach, providing practical examples of the arguments that may be employed in the process of harmonizing European private law. The essays originated during his work with the Commission on European Contract Law (the Lando-Commission ), whose task is the restatement of European contract law. This volume is for comparative lawyers and legal historians.Preface; Abbreviations; Introduction: towards a restatement of the European law of obligations; 1. Contours of a European law of set-off; 2. Liberative prescription I: thl®