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| | Franco Ferrari |
 | | In civil law, not unlike in common law, within the field of civil liability,[1] one generally distinguishes contractual liability from tortious liability,[2] even though some legislatures provide general rules applicable to both contract law and tort law. |
 | | The German Civil Code, for example, dedicates sections 241 through 304 to the Schuldrecht im allgemeinen, [3] i.e., to obligations in general; the Italian Civil Code, unlike the French Civil Code which is based on the Institutionensystem, [4] does so as well in Italian Civil Code articles 1173-1320. |
 | | The German Civil Code (hereinafter BGB) is based on the so called Pandekten-system, according to which a civil code should be divided in different parts: (1) a general part, encompassing rules relating to all kinds of vincula iuris, as well as parts relating to (2) obligations, (3) property, (4) family, and (5) succession. |
| www.cisg.law.pace.edu /cisg/biblio/ferrari9.html (4922 words) |
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