Conclusion
Conclusion
The final method of demonstrating the truth and importance of seeing the common law of torts as based upon the infringement of primary rights is to examine other systems which do not have the same conception. Comparative law, although a dangerous business, sheds light upon the nature of the common law which is a result of the method of its creation. Not only are French and German law structurally different from the common law, this has repercussions for the outcome of many concrete cases which diverge markedly from those which would occur within the common law.
Keywords: French law, German law, delict, comparative law
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