Liability for the Safety of Services

The present research compares the liability rules on injury caused through services provided in the private sector. Although services are generally rendered on a contractual basis the book nonetheless includes both contractual and tortious liability. It focuses, however, on specific kinds of injury, on specific services and on specific countries. The book is only concerned with injury to the person and neither with damage to property nor with pure economic loss. The life, bodily integrity and health of a person are of primary importance in each society.
The book trusts the insights of comparative law and compares therefore eight different legal systems, namely English, French, German, Italian, Spanish, Swedish and US law and also, as far as it already exists, EU law. These legal systems comprise the major legal families which have influenced the law of many other countries and which are generally identified in comparative law. The Common Law family is represented by English law and the law of the United States (although the latter consists of 51 single systems, there is nevertheless a common core of US contract and tort law). Within the Roman branch of the civil law French law was the dominant legal system; however, Italian and Spanish law also belong to this family. The Germanic branch of civil law is represented by German law. Swedish law represents the Nordic legal tradition. EU law is at present in the making and will form a mixed jurisdiction of its own with parts drawn from the sources of all legal families.
The main aim of the comparison is to reveal the similarities and divergences of the legal systems under review in order to lay foundations for a common European law in the field examined.