This chapter carries forward the analysis undertaken in the previous chapters by seeking to identify a number of distinct concepts of the Law of Obligations that emerge from the legal systems previously considered. In this respect, it identifies the basic traits of the Law of Obligations in the Civil Law, the Common Law, the Islamic and the Chinese legal traditions. It concludes that, albeit universally known, the concept of Law of Obligations is far from being a unitary one in the legal traditions examined in this monograph.
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