CANADIAN CONTRACT AND TORT LAW: THE CONCEPT OF FORCE MAJEURE IN QUEBEC AND ITS COMMON LAW EQUIVALENT
Keywords: Common Law, Civil Law, force majeure, frustration, Act of God
AbstractThe present article constitutes a comparative legal study of Canadian tort and contract law concepts. It comments on the concept of force majeure contained in article 1470 of the Quebec civil code and seeks to identify its Canadian common law equivalent in the fields of contract and tort law. Common law terms examined in this regard are the frustration doctrine, and the act of God and inevitable accident defences. The intent of the author is to discover the main differences and similarities between the examined concepts.
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