Specific Performance – and the International Unification of Sales Law

Over the past decades, several approaches have been tried in process of unification contract law to regulate entitlement performance kind, but there is still no generally accepted solution. The Vienna Sales Convention, like its predecessors, resolves question by a quasi-conflict laws rule, essentially making award specific dependent upon forum, thereby undermining results unification. Other sources, such as UNIDROIT Principles, provide autonomous rules that specify detail conditions under which it may be claimed. Draft Common European Law, continues attach primary importance provision obviously also bearing mind interests consumers.