Interpretation of Contracts: Concluding Comparative Observations

Abstract

Abstract A basic knowledge of how contracts are interpreted in other legal systems is not only of interest to the comparatist, but also of enormous relevance for practising lawyers. If a foreign law is applicable to a contractual obligation that law also governs the interpretation of the contract. Moreover, even if English law is applicable, many contracts, particularly international commercial contracts, and their drafts are dealt with by lawyers from other jurisdictions. These lawyers will frequently be tempted to read and understand such agreements using the domestic interpretative devices they are familiar with. It is easy to see how mutual misunderstandings can arise from this process.

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