LE CODE CIVIL DU QUEBEC ET L’AVANT-PROJET OHADA SUR LE DROIT DES CONTRATS

Abstract

This contribution is an outstanding illustration of the Civil Code of Quebec’s international influence. Your Code has greatly inspired entire chapters of the preliminary draft legislation on the codification of contract law which could soon govern, in the framework of a Uniform Act, the 17 African countries in the OHADA (Organization for the Harmonization of Business Law in Africa). We will begin with a brief introduction of the OHADA (I). Next, we will describe the preliminary draft of the Uniform Act on Contract Law, its origins, its method of development, the choice of the UNIDROIT Principles as chief model, and the context in which the Civil Code of Quebec was able to provide an additional source of special inspiration (II). Then we will describe the debates surrounding the preliminary draft and the current outlook (III).