Abstract
The chapter reveals an intricate pattern of similarity and difference, enabling courts and legal writers in Scotland and South Africa to learn from the experience of a kindred jurisdiction. They also, in a number of areas, reveal an emerging and distinctive jurisprudence of mixed systems, and thus suggest viable answers to some of the great questions which must be answered on the path towards a European private law.
| Original language | English |
|---|---|
| Title of host publication | Mixed legal systems in comparative perspective: property and obligations in Scotland and South Africa |
| Place of Publication | Oxford, UK |
| Publisher | Oxford University Press |
| Pages | 469-497 |
| Number of pages | 28 |
| ISBN (Print) | 0199271003 |
| Publication status | Published - 10 Mar 2005 |
Fingerprint
Keywords
- scottish law
- south african law
- jurisdiction
- mixed legal systems
Cite this
Blackie, J. W. G., Farlam, I., Zimmermann, R. (Ed.), Reid, K. (Ed.), & Visser, D. (Ed.) (2005). Enrichment by the act of the party enriched. In Mixed legal systems in comparative perspective: property and obligations in Scotland and South Africa (pp. 469-497). Oxford, UK: Oxford University Press.