The “restrictive,” “adaptive” and “collateral” approaches to a duty of good faith ' which were 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),
Franchise Agreements and the Duty of Good Faith In European Civil Law
The two primary "families" of civil law in Europe are German and French, and each approaches the concept of good faith in a different way. Last month we took a look at the German system; now, we turn to the French.
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