SGA개정안과 CISG의 비교연구

The Sale and Supply of Goods to Consumers Regulations 2002 in Comparison with the United Nations Convention on International Sale of Goods 1980

This study primarily concerns the Sale and Supply of Goods to Consumers Regulations 2002, focusing on the newly amended rules of the Sale of Goods Act(1979). It describes and analyzes the provisions of Regulations 2002 in a comparative way in order to provide legal advice to the sellers who plans to enter into English consumer markets. It also attempts to compare the rules of Regulations 2002 with those of CISG and to evaluate them in light of the discipline of Law and Economics the basic question of which is whether a solution from one jurisdiction may enhence 'efficiency', serving the goal of reducing negotiation costs through providing a set of default terms, and through imposing an efficient solution which may assist value maximizing exchange where disputes arise.