文档介绍：DIFFERENT DEGREES OF CONVERGENCE:
parison of Tort Law (Example:
Fairchild v. Glenhaven Funeral Services) and Property Law(1)
Sjef van Erp (Maastricht University)(2)
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Contents
I What is 'convergence'?
II Tort law: Fairchild v. Glenhaven Funeral Services Ltd.
III Property law
IV Concluding remarks
Notes
I What is 'convergence'?
The topic of convergence as such cannot even superficially be discussed within the limits given to me. What I intend to offer are some thoughts about convergence and apply these to tort law and the law of property in a broad sense (including personal and real property law).
In Europe the word 'convergence' is most frequently used parative lawyers discuss ing together of European continental civil law and non-mon law. The 'civil law' systems are those which are influenced by Roman legal thinking prise the French, German and Scandinavian legal traditions. When the 'common law' is referred to, usually English or mon law is meant. We tend to forget that mo