Changing Contract Lenses: Unexpected Supervening Events in English, New Zealand, U.S., Japanese, and International Sales Law and Practice

Luke Nottage
Faculty of Law
University of Sydney

This article compares differences in the reasoning underlying contractual relationships between English and New Zealand law and U.S. and Japanese law. It then builds upon an existing framework by adding the notion of didactic formality to identify another important contrast between the laws of these countries. It also discusses how CISG and UPICC fit in to this spectrum. The article concludes by questioning “strong convergence” theory in commercial law worldwide.

See other articles in Volume 14, Issue 2. Bookmark the permalink.