University Of East Anglia

Norwich Law School

LAW- M585
FOUNDATIONS OF
INTERNATIONAL COMMERCIAL LAW I
PG COURSEWORK 2009-2010
STUDENT REGISTRATION NUMBER [4230531]
The twentieth century saw the resurgence of a truly transnational commercial
law and all the indications are that the twenty first century will be the century of a
truly global commercial law!
D"#$%##&
WOR !OUNT "#$%
T'()* O+ C,-.*-.#
&' (ntroduction "
)' Nature of The Transnational !ommercial Law' "
)'&' efinition of Transnational !ommercial Law' "
)')' The (m*ortance of Transnational !ommercial Law' +
)'"' The Role of ,erchants in !om*rising Transnational !ommercial Law' %
)'+' The -istory of The Transnational !ommercial Law' $

"' The Resurgence of Transnational !ommercial Law in the).
th
!entury' /
"'& The (m*act of 0olitical and Economical !hanges on Transnational /
!ommercial Law'
"') E1am*les of The 0ros*erity of Transnational Law in The ).th !entury' /
"'" The Urge of The 0ros*erity of Transnational Law in The ).
th
!entury' 2
+' The 3lobal !ommercial Law' #
+'&'The Theory of 3lobal !ommercial Law' #
+')' The 4ertility of The a**roaches of 3lobal !ommercial Law' &.
%' !onclusion &&
$' 5ibliogra*hy &)
)
1& I-./,0%$.",-
(t is generally recognised that the transitional commercial law has e1*erienced a dramatic transition
during the twentieth century' This transition was not coincidental' (n fact6 there are many economic
as well as *olitical factors that could be involved in this legal revolution' (n addition some scholars
claim that this continuing transition is high li7ely to lead us towards a global commercial law& This
essay will attem*t to *rovide a *rofound analysis of the transition of transitional commercial law6
*articularly in the twentieth century and also e1amine the conse8uences that may result later from
this transition' (n doing so6 ( will *rovide a brief overview of the nature of transnational commercial
law including definition 6sources and historical bac7ground' Then ( will consider the resurgence of
transnational commercial law in ).
th
century by focusing on the im*act of *olitical and economic
changes on the transnational commerce law' Also6 ( will *resent a number of e1am*les of the
*ros*erity of transnational commercial law in that century' After that ( will *roceed to evaluate
whether such legal transition could be culminated in creating global commercial law in the )&th
century' 4inally6 ( will *rovide several sets of conclusions'
2& N'.%/* ,+ T1* T/'-#-'.",-') C,22*/$"') L'3
2&1& D*+"-".",-
While a variety of definitions of the *hrase transnational commercial law have been suggested6 this
*a*er will use the definition first suggested by 3oode who saw it as9 'Set of private law principles
and rules, from whatever source, which governs international commercial transactions and is
common to legal systems generally or to a significant number of legal systems'.
1
Three sets of
conclusions can be drawn from his definition' 4irst6 transnational commercial law 6in essence6 evolve
around *rivate law which could mean in this conte1t the rules and regulations devised by citi:ens or
legal entities of different nations' The transnational commercial law6 therefore6 could be seen as a
s*awn of the convergence of considerable number of ;urisdictions' Second6 the sub;ect of
transnational commercial law is merely cross<border transactions' Thus6 it is not necessary to be
similar to the national commercial law besides it may deal with different sorts of intricate issues
which *robably not seen in local law' Third6 the transnational commercial law needs to be
recognised and ratified from considerable number of nations before coming into o*eration 6otherwise
there will not be a genuine value of its law
)
' These *oints raised above would be the intrinsic features
&
See Roy 3oode6 -erbert =ron7e and Ewan ,cendric76 Transnational Commercial Law: Tet, Cases and !aterials
>OU06 O1ford )../? * +
)
See Alastair ,ullis6 "hy harmonise transnational commercial law > University of East Anglia )..# ?
"
of transnational commercial law and could *resent an outline for the nature of transnational
commercial law' -owever6 the obvious 8uestion may arise in this conte1t is why we need
transnational commercial law' (n other ward to what e1tent transnational commercial law is
im*ortant'
2&2& T1* I24,/.'-$* O+ T/'-#-'.",-') C,22*/$"') L'3
The im*ortance of transnational commercial law reflected in its benefits to international trade' These
benefits could be observed clearly through four factors' 4irst6 reduction of legal ris7s and the
transactions costs which often involved in international commerce' ue to the nature of international
trade law which entails considerable number of ris7s6 *arties are bound to be concerned about the
a**licable law and ;urisdiction in case things go wrong' Also they bear in mind issues such as
mandatory law6 government interference6 *ublic *olicy etc' These inherent ris7s in turn leads to
increasing the e1*enses of international trade transactions' Transnational commercial law *lays
*ermanent role in reducing these ris7s as well as its associated e1*enses through unifying the
multi*le ;urisdictions governing the whole international commerce *rocess
"
' Second6 the 0rotection
of fledging *arties' 3iven the wide diversity of legal systems mastering the international commerce6
the ris7 of e1isting divergence among these systems is very high' Such divergence could be used
o**ortunistically from some *arties' So6 transnational commercial law is very li7ely to be a
contributing factor in *recluding fledgling *arties from falling *rey to this o**ortunism and hostility6
than7s to the high level of certainty and clarity *rovided by transnational law
+
'
Third6 refinement of the commerce law' 5y virtue of the *rocess of ma7ing transnational commercial
law which involved many talent e1*ertise from all over the world6 the 8uality of these devised laws
is high' These high 8uality laws are not ;ust ta7ing *art in facilitating international commerce but
also filling the legal vacuum6 which may e1ist in national legal systems dealing with cases which
have a foreign element6 through *resenting neutral commercial rules tailored to meet the
international trade needs
%
'
"
See Roy 3oode6 -erbert =ron7e and Ewan ,cendric76 Transnational Commercial Law: Tet, Cases and !aterials
>OU06 O1ford )../? * &#)' Also6 Alastair ,ullis6 A Ty*ical (nternational Trade Transaction > University of East Anglia
)..# ?* )<%
+
See Roy 3oode6 -erbert =ron7e and Ewan ,cendric76 Transnational !ommercial Law9 Te1t6 !ases and ,aterials? *
&#)' Also6 Alastair ,ullis6 A Ty*ical (nternational Trade Transaction > University of East Anglia )..# ?* )<%
%
See 0aul 5' Ste*han6 @The 4utility of Unification and -armoni:ation in (nternational !ommercial Law@ Afall &##2B
Cirginia Dournal of (nternational Law /+"6/+"</%.' Also6 Alastair ,ullis6 "hy harmonise transnational commercial law >
University of East Anglia )..# ?'
+
The fourth factor is the dissemination of legal 7nowledge' Regardless of the efficacy of the
transnational commercial law or not6 legal advisers from all over the world will find themselves
driven to understand these s*ecific wides*read laws and their a**lications6 besides the conformity of
these laws to their national law or not' This need will hel* to disseminate legal 7nowledge in a more
com*rehensive and broader way' Also it may be a good o**ortunity to narrow the wide ga* between
international attorneys themselves which may arise naturally due to cultural and linguistic diversity
among these lawyers' (n order to master these laws6 lawyers will see7 to wor7 with other attorneys
around the world' As a result of such legal coo*eration6 as well as com*rehensive understanding of
the international commercial law6 the *roducts of legal counsels almost certain to be im*roved which
6 res*ectively6 will affect the world trade
$
'
2&3& T1* R,)* ,+ M*/$1'-.# "- $,24/"#"-5 ./'-#-'.",-') $,22*/$"') )'3
4or the sa7e of com*rehensive understanding of the transnational commercial law6 it is vital to
recogni:e that the *ur*ose of commercial law6 in general6 was to meet merchants legitimate and
*ractices re8uirements' (t is6 therefore6 fair to say that the main source of commercial law is
merchants themselves in tandem with international legislation ' The commercial law could be seen as
a *roduct of their *eculiar way to left the trade barriers which they may encounter while *roducing
their *roducts6 whether it were goods or services6 in a more attractive6 com*etitive and cost<effective
forms' 4or e1am*le6 the forming of the bill of lading @a document signed on behalf of the com*any
carrying the goods6 ac7nowledging that the goods have been shi**ed on board a *articular vassel
bound for a *articular destination and stating the terms on which the goods are received@
/
6in general6
was as a res*onse to the middle ages merchants needs' 5ecause of the lac7ing of a s*ecific
mechanism through which the goods could be sold in transit6 merchants created the bill of lading
which *rovides an absolute control of the goods to whoever the holder of the bill of lading6 even
before the goods have actually arrived' This fle1ible mercantile mechanism entitled the buyer of the
goods to sell them in transit or even use the bill of lading as collateral for a loan
2
' This *revious
e1am*le e1*licitly showed to what e1tent transnational commerce law is derived from merchants
needs6 customs and usages'
$
See 0aul 5' Ste*han6 @The 4utility of Unification and -armoni:ation in (nternational !ommercial Law@ Afall &##2B
Cirginia Dournal of (nternational Law /+"6/+"</%.
/
See Alastair ,ullis6 A Ty*ical (nternational Trade Transaction > University of East Anglia )..# ? * ).'
2
See Roy 3oode6 -erbert =ron7e and Ewan ,cendric76 Transnational !ommercial Law9 Te1t6 !ases and
,aterials * $6/'
%
2&4& T1* 6"#.,/7 ,+ T1* T/'-#-'.",-') C,22*/$"') L'3
(t is certainly correct that transnational commercial law has been e1istent since immemorial time' 5y
one way or another the commercial law often is cou*led with international trade due to its vital role
in facilitating such trade' The !ode of -ammurabi 6believed to date bac7 to &#.. 5!6 could be
considered as the oldest e1isting commercial law' This code has indeed many of the rules of
commercial law which affect both local and international trade' (n the second or third century 5!6
the e1isting of transnational commercial law could be more discernible through the Rhodian
,aritime !ode which was acce*ted by 3ree7s and Roman and lasted somehow&6... years' This
code constitutes the first 7nown law to re*resent the *rinci*les of general average in maritime
insurance' 5etween the eleventh and fifteenth centuries6 a number of com*ilations have a**eared
such as Rolles of Oleron 6in the twelve centuryE 5lac7 5oo7 of the Admiratly 6in the med< thirteenth
centuryE the Laws of Wisby6 in the fourteenth centuryE and6 the !onsulate of the Sea 6 in the
fourteenth or fifteenth century
#
' The main sub;ect of these com*ilations above is maritime law'
Notably6 le1mactoria >mercantile customs and usages? could be a *redominant factor by which these
com*letions were formed'
Also6 one of the most e1*licit evidence in this field is The 3reat 4airs of Euro*e' The *owerful
contribution of these medieval centuries fairs in develo*ing merchant law is undeniable' These fairs
have not ;ust facilitated international commerce through devising a significant number of
transnational commercial laws but also have *layed a *ermanent role in creating conducive
environment for international transactions6 by s*orting the ideas of good faith and loyalty' With the
*assage of time this conducive environment led to increased international commerce6 which in turn
increased the issuance of transnational commercial laws in order to maintain the security element
and the high level of the regulations of these fairs
&.
'
#
See Roy 3oode6 -erbert =ron7e and Ewan ,cendric76 Transnational !ommercial Law9 Te1t6 !ases and ,aterials
>OU06 O1ford )../? * &)6&"'
&.
See 0< -uvelin6 Essai histori8ue sur le droit des marchFs et des foires >0aris6
&2#/? %#+</'
$
3& T1* /*#%/5*-$* ,+ ./'-#-'.",-') $,22*/$"') )'3 "- .1* 20
.1
$*-.%/7&
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(t is conceded that the twentieth century saw a considerable number of radical changes on several
levels in the whole world' On the *olitical level6 world war ( and the second besides the de<
colonisation decades >between &#$.s and &#/.s? were enough to change the *olitical ma* of the
world' As a result of these changes6 three worlds were formed' (n addition6 the colla*se of the Soviet
Union in &##.s' And the enormous increase in the number of members of the United Nations > from
%. states in the &#%.s to &22 states in the late &##.s?' These *olitical events in one way or another6
have contributed in forming a new transnational commercial law' The advent of a number of mar7ets
and its legal regimes could be seen also as a *relude to the legal revolution' This revolution
stemming manly from national laws6 foreign laws and transnational law which were devised by
international formulating agencies' As a result6 considerable numbers of transnational laws were
drafted in the first half of the ).
th
century by relatively a limited number of states6 as many states
had not ac8uired their inde*endence yet '
&&
(n the second half of the ).
th
century6 in the wa7e of many countries gaining their inde*endence and
formulating their own legal systems6 as well as an increased incidence in emerging mar7ets6 the
desire to com*rise a new neutral transnational commercial laws has been increased' The needs for
unified trade regulations sensitive to natural diversity among these mar7ets became more urgent
*articularly with the buoyancy of international trade in that time'
&)
This desire has been inter*reted
later *rimarily by creating a number of global conventions such as UN(RO(T6 UN!(TRAL and
-ague !onference6 as well as regional agreements such as the Organi:ation of American States
>OAS? and the Euro*ean !ommunity >E!?'
3&2 E8'24)*# ,+ .1* 4/,#4*/".7 ,+ ./'-#-'.",-') $,22*/$"') )'3 "- .1* 20
.1
$*-.%/7
(n the late twentieth century6 transnational commercial law had been *romoted by generating a wide
s*ectrum of conventions' The eminent transnational laws enacted by such conventions had ho*ed to
7ee* *ace with rising economic growth and concomitant regulations needs at that stage' There are
many success stories in this field' The cross<border contract law devised by the United Nations
!onvention on !ontracts for the (nternational Sale of 3oods >founded in &#22?was a loud e1am*le
of the modern legal transition in the ).
th
century' This convention had ratified as a law in %+
&&
See Lu7as ,istelis6 @Regulatory As*ects9 3lobali:ation6 -armoni:ation6 Legal Trans*lants6 and Law Reform < Some
4undamental Observations@ As*ring )...B#nternational Lawyer &%$6&%/
&)
See Lou7as ,istelis6 (s -armonisation a Necessary EvilG> Sweet H ,a1well )..&?
/
countries and (ts contract of sale has been considered as the most essential commercial contract' (t is
worth menting that this transaction contract law is in reality a *ure international law' Remar7ably6 it
is not derived from any national or foreign laws
&"
' Also6 the (nternational (nstitute for the unification
of *rivate laws6 7nown as UN(RO(T6 was founded in &#$) as an organ of the league nations' (n
&#+. after the end of the league6 the UN(RO(T was re<founded on the basis of a multilateral
agreement >statue of UN(RO(T? which was amended in &##"' At *resent the number of member
states of UN(RO(T is si1ty<one member from all over the world' This organisation still
contributes in considering ways of unifying and coordinating the national *rivate laws6 and to set u*
*rogressively for the international acce*tance of transnational laws
&+
'
Another success story is the United Nations !ommission of (nternational Trade Laws >UN!(TRAL?
which was founded by the 3eneral Assembly of the United Nations in &#$$' The effects of
UN!(TRAL on *romoting transnational commercial law could be divided into two distinct
functions' The first function is to *rovide many commercial legislations and rulings which codify the
commercial *rocesses worldwide' The second function is unifying and coordinating the transnational
commercial laws and conventions among the international commercial community which
*resumably reflect *ositively on commercial *rogression for the member states
&%
' These conventions
raised above ta7e a vital *art in the develo*ment of substantive transnational commercial law not ;ust
by *roviding a considerable number of transnational commercial rules but also through rising the
8uality of these laws' Than7s to the international e1*ertise involved in such conventions' (n addition
the success of these institutions and other global conventions was basically due to a willingness by
the international trade community to *rovide a number of rules governing international commercial
transactions'
3&3 T1* %/5* ,+ .1* 4/,#4*/".7 ,+ ./'-#-'.",-') $,22*/$"') )'3 "- .1* 20.1 $*-.%/7
One of the main reasons for this high lea* of the transnational commercial laws in the twentieth
century may be lied in international im*ulse' The as*iration to left the international trade barriers
6namely national frontiers was overridden' This international as*iration mainly includes two *rime
elusive goals' The first is to generate an international devised legal system dealing with cross<border
&"
See A Watson6 @Legal trans*lants and Euro*ean *rivet law@ >ecember )...? +'+ ED!L
<htt*9IIwww'e;cl'orgIe;clI++I++<)'html> accessed ). ec )..#
&+
See Roy 3oode6 -erbert =ron7e and Ewan ,cendric76 Transnational !ommercial Law9 Te1t6 !ases and ,aterials
>OU06 O1ford )../? * &"+6)."'
&%
See United Nations6 @The UN!(TRAL 3uide 5asic facts about the
United Nations !ommission on (nternational Trade Law@>United Nation publication6Cienna )../? * )'
2
transactions6 at the same time does not e1*ose to national laws to local transactions' This *ur*ort has
been achieved by creating a number of global conventions' The second *ur*ort is to find a common
*olitical and economic ground by which transnational commercial law would govern the local
transactions besides the cross<border transactions' Thus6 the barrier of national frontiers would begin
to fade
&$
' This *ur*ort has been fulfilled by forming many regional agreements' -owever6 such
motivation is not very li7ely to lead the world community to create and acce*t a conce*tion of global
commercial laws for many *ractical reasons'
4& T1* G),(') C,22*/$"') L'3&
4&1&T1* T1*,/7 ,+ G),(') C,22*/$"') L'3
The *ur*ort of the global commercial law may indicate a set of commercial rules ado*ted
internationally and a**lied domestically all over the world' This universalistic view of law a**eared
clearly with com*arative law studies which had been set out in 0aris in &##. by two well<7nown
4rench ;urists EOUAE LA,5ERT and RAJ,ON SALE(LES who showed enthusiasm
towards *romoting a universal common law through com*arative law studies9
A world law must be created<not today 6*erha*s not even tomorrow<but created it must be6
and com*arative law must create it' As LA,5ERT *ut it ''' com*arative law must resolve the
accidental and divisive differences in the laws of *eo*les at similar stages of cultural and
economic develo*ment6 and reduce the number of divergences in law6 attributable not to the
*olitical6 moral or social 8ualities of the different nations but to historical accident or to
tem*orary or contingent circumstances'
&/

-owever6 This universalistic theory has attracted many criticisms and its realistic is 8uestionable'
5asically6 This theory *remised on a doctrine of the unity of human7ind but the facts of life is6 such
theory is very li7ely to be overambitious' There are many intrinsic differences in national mind<sets
as a natural result of the e1istence of diversity in languages6 traditions and habits as well as the
variations in legal systems dut to its sources6 structures and techni8ue differences
&2
' ,oreover6 some
legal systems6 at the *resent6 are derived mainly from religions such as (slamic law' So6 it is very
difficult if not im*ossible to create universal law on the basis of com*romising'
&$
See Roy 3oode6 Reflection on the harmonisation of !ommercial law > OU0 &##. ?
&/
See =onrad Kweigert and -ein =ots6 $n #ntroduction to Comparative Law6 (Tony Weir tr)(3
rd

edn,Clarendon Press, Oxford,1988)2-3
&2
See -arold 3utteridge6 Comparative law: an introduction to the comparative method of legal study,%&
nd
edn,
Auvermann6&#/&?$</
#
4&2& T1* F*/.")".7 ,+ T1* '44/,'$1*# ,+ G),(') C,22*/$"') L'3#&
5asically6 the global commercial law could be achieved through three main suggested methods' 4irst6
by international ado*tion of a s*ecific uniformed substantive law governing the international
transactions or both domestic and international transactions' This method is time consuming' 3iven
to the dis*arity between the legal cultures6 the re8uired time to elicit a necessary su**ort for such
universal substantive law is e1cessive long and discouraging' 4or e1am*le6 the success of the United
Nations !onvention on !ontracts for the (nternational Sale of 3oods >!(S3? could be seen as a
*roduct of twelve years of international co<ordinations > from &#$2 to &#2.?' 4urthermore6 in the
way toward uniformed substantive law6 o*timal rules6 which domestically im*roved by local
e1*ertise6 may be ;ettisoned6 as the *rice of *roducing such global law
&#
' Second6 international
ado*ting of uniformed choice of law rules in which the *arties could select a *articular substantive
national law to govern their transactions >irres*ective of any other essential elements such as the
location of dis*ute?'
).
Such method are neglecting the sensitivity of sovereignty issues which may
arise by a**lying a choice of law rules' (n other words6 the reluctance of embracing the conce*tion
of choice of law is *redominant among legal systems which *refer to wield enormous influence by
a**lying their sets of rules >mandatory rules? in order to remain the @national interest@' So6 its
generally agreed that as long as global conventions do not e1*ose to sovereignty issues6 the
*ossibility of success such conventions is high'
)&

Third6 by enforcing a su*ranational @ le1 mercatoria@' (n the last thirty years6 many Euro*ean scholars
alleged that there are a sufficient commercial rules and general *rinci*les derived from le1
mercatoria >mercantile customs and usages? which could regularise the international commercial
contracts' This argument is *remised on the fact that arbitrators often draw u*on the customs and
general *rinci*les of merchants in dealing with contract dis*utes' Notwithstanding6 it could be
argued that !(S3 is an o*timal alternative and *ractical solution then le1 mercatoria because of the
widely acce*ted of !(S3' Whereas the le1 mercatoria lac7ing of such international acce*tance6
besides that le1 mercatoria is still unwritten'
))
(n the light of these shortcomings6 it is fair to say that
the ca*ability of these methods to achieve a global commercial law are under consideration'
&#
See 0aul 5' Ste*han6 @The 4utility of Unification and -armoni:ation in (nternational !ommercial Law@ Afall &##2B
Cirginia Dournal of (nternational Law /+"6/+"</%.
).
See Dohn A' S*anogle6 @The arrival of international *rivet law@ A&##&<&##)B 'eorge "ashington (ournal of
#nternational Law and )conomics +//6+2$
)&
See Lou7as ,istelis6 (s -armonisation a Necessary EvilG> Sweet H ,a1well )..&?
))
See Dohn A' S*anogle6 @The arrival of international *rivet law@ A&##&<&##)B 'eorge "ashington (ournal of
#nternational Law and )conomics +//6+2$' Also6 See Roy 3oode6 -erbert =ron7e and Ewan ,cendric76 Transnational
!ommercial Law9 Te1t6 !ases and ,aterials * $6/'
&.
5& C,-$)%#",-&
This assay has briefly e1*lored the nature of the transnational commercial law as a *relude and a
condition to the consideration of ,anifestations of 6and reasons for the return of international law in
the last century' Also6 it e1amined the allege that the )&th century could be the century of global
commercial laws' 4ourth sets of conclusions can be drawn from the e1*osition above and some
forecasts will also be attem*ted' 4irst6 there are no doubts that transnational commercial law has
made a great *rogress in the last century' This great *rogress is evident in the number of global
conventions which have been held6 as well as in regional agreements' The truly international
willingness and the need of new transnational commercial law can accommodate the surge in
international trade at that stage6 both have contributed in develo*ing transnational commercial law in
the )&th century' Second6 it could be observed from this dramatic transition in the ).
th
century that
@national *ride@ did not hold as much weight as today' The sensitivity of globali:ation was not a
hinder to embrace internationally devised law'
)"
On the contrary6 in this century many countries tend
to be averse to embrace none national commercial law because of their desire to *reserve their
@national identities@'
)+

Third6 it would a**ear that the a**roaches to achieve a com*lete global commercial law in this
century are sterile' The cultural and *olitical hurdles are still very hard to ;um*' ,oreover6 the
com*romise *rocess to achieve such global law may involve many demerits' 4ourth6 it could be
argued that the near global conventions might be the o*timal alternative of global law6 owing to the
discernable ca*ability of global conventions in raising the balance in favour of economic interests
com*ared with or against maintaining the national identity'
)"
%+ countries have ratified the United Nations !onvention on !ontracts for the (nternational Sale of 3oods6 although it
is *urely international law'
)+
See 0aul 5' Ste*han6 @The 4utility of Unification and -armoni:ation in (nternational !ommercial Law@ >&###?
University of Cirginia School of Law 0a*er No' ##<&.'
&&
5(5L(O3RA0-J 9
Roy 3oode6 -erbert =ron7e and Ewan ,cendric76 Transnational !ommercial Law9 Te1t6
!ases and ,aterials >OU06 O1ford )../?
0aul 5' Ste*han6 @The 4utility of Unification and -armoni:ation in (nternational !ommercial
Law@ Afall &##2B Cirginia Dournal of (nternational Law
Lu7as ,istelis6 @Regulatory As*ects9 3lobali:ation6 -armoni:ation6 Legal Trans*lants6 and
Law Reform < Some 4undamental Observations@ As*ring )...B(nternational Lawyer
Lou7as ,istelis6 (s -armonisation a Necessary EvilG> Sweet H ,a1well )..&?
A Watson6 @Legal trans*lants and Euro*ean *rivate law@ >ecember )...? +'+ ED!L
Lhtt*9IIwww'e;cl'orgIe;clI++I++<)'htmlM accessed ). ec )..#
Roy 3oode6 Reflection on the harmonisation of !ommercial law > OU0 &##. ?
=onrad Kweigert and -ein =ots6 An (ntroduction to !om*arative Law6 >Tony Weir tr?>"rd
edn6!larendon 0ress6 O1ford6&#22?
-arold 3utteridge6 !om*arative law9 an introduction to the com*arative method of legal
study6>)nd edn6 Auvermann6&#/&?
Dohn A' S*anogle6 @The arrival of international *rivate law@ A&##&<&##)B 3eorge Washington
Dournal of (nternational Law and Economics
United Nations6 @The UN!(TRAL 3uide 5asic facts about the United Nations !ommission
on (nternational Trade Law@>United Nation *ublication6Cienna )../?
Alastair ,ullis6 A Ty*ical (nternational Trade Transaction > University of East Anglia )..# ?
Alastair ,ullis6 Why harmonise transnational commercial law > University of East Anglia
)..# ?
&)