Leistungsstörung und Haftungsbefreiung

The countries of Europe are under increasing pressure to unify their laws of obligations. In the law pertaining to interference with the performance of an obligation, Anika Mitzkait compares the two most modern sets of regulations: the reformed German law of obligations and the (non-governmental) Principles of European Contract Law. The purpose of this comparison is not only to examine the extent of the approximation between German law and the standards of the PECL. The author's main concern is a real competition between systems in the form of an evaluated comparison, i.e. to find answers to the questions of which model seems to be more convincing from a dogmatic standpoint and on the basis of its results.