Strict Liability
Strict Liability
This chapter analyses the concept of strict liability in Europe. It shows that the difference between fault liability and strict liability is a gradual rather than a principle one. When finding rules, courts and legislators in all jurisdictions use different elements from both categories to achieve the best mix. However, what is considered to be the best mix differs throughout the legal systems. France prefers it with many elements of strict liability whereas England prefers it with a huge amount of negligence elements. Three variations on strict liability are considered: liability with an extra debtor, liability for a defective object, and liability with a limited defence.
Keywords: strict liability, Europe, extra debtor, defective object, negligence, fault liability, France, England
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