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.

11 minute read May 01, 2014 at 02:29 PM

Mark Abell

Franchise Agreements and the Duty of Good Faith In European Civil Law

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), despite the fact that some of them have very different historical perspectives and approaches to the concept of good faith.

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