The “restrictive,” “adaptive” and “collateral” approaches to a duty of good faith ' which we discussed in Part One of this article last month ' can be found in differing combinations and degrees in most of the civil jurisdictions in the European Union (EU), despite the fact that some of them have a very different historical perspectives and approaches to the concept of good faith.
European Civil Law, Franchise Agreements and the Duty of Good Faith
The "restrictive," "adaptive" and "collateral" approaches to a duty of good faith can be found in differing combinations and degrees in most of the civil jurisdictions in the EU, despite the fact that some of them have a very different historical perspectives and approaches to the concept of good faith. Last month we took a look at the German system; now, we turn to the French.
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