Comparative Foundations of a European Law of Set-Off and Prescription

The emergence of a European private law is one of the great issues on the legal agenda of our time. Set-off and 'extinctive' prescription (or limitation of actions) are much neglected topics in comparative literature. Professor Zimmermann provides practical examples of the arguments that may be employed in the process of harmonising European private law on a rational basis: he considers the comparative experiences in different national legal systems, the way in which the international development is heading and an existing common core of values, rules and concepts. He concludes by mapping out a model for a common European approach as the basis for a set of supra-national principles. This volume will interest comparative lawyers and lawyers interested in European law, as well as legal historians. These essays originated during his work with the Commission on European Contract Law (the 'Lando-Commission'), whose task is the 'restatement' of European contract law.

Reinhard Zimmermann is Professor of Law at the University of Regensburg.