The concept of “good faith” exists in most civil law jurisdictions but is frequently interpreted in different ways.
What Can U.S. Legislators Learn from the European View of Good Faith?
The concept of "good faith" exists in most civil law jurisdictions but is frequently interpreted in different ways. Common law jurisdictions, such as the United States, however, generally have an uneasy relationship with the concept of a duty of good faith, as is illustrated by the case law and proposed legislation.
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