This major reference work compares the formation of contract in the legal systems of England, France, Iran and other Islamic systems. The Preliminary Part gives a historical sketch and describes the sources of law of the four legal systems. It then describes the development and general theory of contract law in the four systems. Part One then analyses in detail the basic notions of formation of contract including the range of psychological elements and their means of expression. The author then goes on to describe and compare the function and determination of offer and acceptance in the four legal systems. Part Two analyses the mechanism of formation and import of a contract in respect of both offer and acceptance. The book has been extensively researched and includes references to Roman law and other modern legal systems. The work has been meticulously indexed and cross-referenced.
Preliminary Part: Generalia. Section I: Historical Sketch of the Four Legal Systems. I : Outline of Each Legal System's History. II: Comparative Observations on the Historical Developments of the Four Legal Systems Section II: Sources of the Law under the Four Legal Systems. I: Sources under Each Legal System. II: Summary, Assessment and Comparison on Sources under the Four Legal Systems. Section III: Initiation to Contract(s); Development and General Traits. I: Genesis and Evolution of the Law of Contract(s). II: Law of Contracts and General Theory of Contract. III: Purview of the Law of Contract(s); and Related Conceptualisation, Terminology and Classification. Part One: Basic Notions Relating to the Formation of Contract(s). Section I: Legal Notion of Psychological Elements. I: Range of Psychological Elements. II: Exteriorisation of Psychological Elements; Objectivity versus Subjectivity. III: Means of Expression of Psychological Elements. IV: Silence; Question of Efficacy. Section II: Function and Determination of Offer and Acceptance . I: Offer and Acceptance in French and English Law. II: Offer and Acceptance in Islamic (Shi'ah) Law. III: Offer and Acceptance in Iranian Law. IV: Summary and Comparison of the Doctrine of Offer and Acceptance under the Four Legal Systems. Part Two: Mechanism of Formation and Import of a Contract. Section I: Offer. I: Definiteness and Communication of Offer. II: Duration and the Question of Revocation of Offer. III: Termination of Offer. Section II: Acceptance. I: Certainty and Conformity of Acceptance. II: Correlation of Acceptance with the Offer. III: Communication of Acceptance; French and English Law Compared. IV: Communication of Acceptance under Islamic Law; Contrasted. V: Communication of Acceptance under Iranian Law; Compared with French and Islamic Law. VI: The Time and the Place of Acceptance and of Contract; Comparatively Treated. Section III: Import of a Contract. I: Minimum Terms Required. II: Interpretation. Appendices. Index.