Vicarious Liability in Tort: A Comparative Perspective
Oct 2010 · Cambridge Studies in International and Comparative Law Book 69 · Cambridge University Press
Ebook
331
Pages
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About this ebook
Vicarious liability is controversial: a principle of strict liability in an area dominated by fault-based liability. By making an innocent party pay compensation for the torts of another, it can also appear unjust. Yet it is a principle found in all Western legal systems, be they civil law or common law. Despite uncertainty as to its justifications, it is accepted as necessary. In our modern global economy, we are unlikely to understand its meaning and rationale through study of one legal system alone. Using her considerable experience as a comparative tort lawyer, Paula Giliker examines the principle of vicarious liability (or, to a civil lawyer, liability for the acts of others) in England and Wales, Australia, Canada, France and Germany, and with reference to legal systems in countries such as the United States, New Zealand and Spain.
About the author
Paula Giliker is Professor of Comparative Law at the University of Bristol, where she specialises in comparative tort law. She has previously taught at the University of Oxford and Queen Mary, University of London. She is also a qualified barrister and visiting lecturer at the Universities of Hong Kong and Valencia.
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