By Edwin A Notley
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Additional resources for A Comparative Grammar of the French, Italian, Spanish and Portuguese Languages
Giust. civ. massimario Entscheidungen des Bundesverfassungsgerichts (Decisions of the Federal Constitutional Court) Bundesverfassungsgerichtsgesetz (Statute of the Constitutional Court of Germany) Decisions of the English Court of Appeal Cour de cassation Code Civil (French Civil Code) Law Reports, Chancery Division (from 1891) Cambridge Law Journal Commonwealth Law Reports Codice di procedura civile (Code of Civil Procedure) Council of State (Supreme Administrative Court) Corte di Cassazione (Supreme Court for Civil and Criminal Matters) Corte costituzionale (Constitutional Court) Critica penale Danno e responsabilit` a Der Betrieb (Law Review) Deutsches Steuerrecht Einf¨ uhrungsgesetz zum BGB (Introductory Law to the BGB) European Law Reports Europ¨ aische Grundrechtezeitung England and Wales Court of Appeal, Civil Division (online Reports of Judgments of the Court of Appeal) Law Reports, Exchequer Division (1875–80) Zeitschrift f¨ ur das gesamte Familienrecht Family Cases Reports Family Law Reports Federal Supplement (American Law Reports) Federal Reporter, 2nd series (American Law Reports) Foro italiano Grundgesetz (Constitution of Germany) Giustizia civile Massimario della giustizia civile abbreviations ICLQ INAIL IRLR JA J Leg.
This second consequence not only makes the comparative exposition of different laws difficult; it can also make the comparison of awards misleading since often one may not be comparing ‘apples with apples’ but ‘apples with oranges’. The common law terms are often side-products of pleading rules and the use of juries in civil law trials (now almost extinct in the English but not the American common law) may have nothing to do with policy decisions taken at the level of substantive law. Two sets of such terms will make our point; and the picture will be further clarified in the account that will follow in chapters 2 to 4.
35) or other mechanisms of immediate social help for injured persons (combined with the right of recourse against the tortfeasor); and by the emergence of the substantial body of statutory regulation outside of the BGB which – for specific areas – tends to push the fault principle further back and in many instances establishes strict liability. The administration of tort law in Germany has always been in the hands of professional judges. There is no jury in civil cases. This has consequences for the amount of damages awarded to victims (see p.
A Comparative Grammar of the French, Italian, Spanish and Portuguese Languages by Edwin A Notley