A Comparative Study on the Legal System of the Industrial Injury Compensation and Insurance in Korea and China

2018 ◽  
Vol 34 (4) ◽  
pp. 3-25
Author(s):  
Gyo-sook Kim
Keyword(s):  
Comparative Study ◽  
Legal System ◽  
Industrial Injury

Consumer Protection in Jordanian Discount Sales: A Comparative Study with the Legislations of France, Tunisia and the United Arab Emirates

2021 ◽  
pp. 1-16
Author(s):  
Tariq Kameel ◽  
Fayez Alnusair ◽  
Nour Alhajaya
Keyword(s):  
Comparative Study ◽  
United Arab Emirates ◽  
Consumer Protection ◽  
Legal System ◽  
Judicial Practice ◽  
Consumer Rights ◽  
Market Protection ◽  
Market Intervention ◽  
Constituent Elements ◽  
Shed Light

Abstract This article compares consumer protection in the framework of discounts with the constituent elements of such sales and the relevant methods of protecting consumer rights, according to French, Emirati, Jordanian, and Tunisian legislation and judicial practice. The findings shed light on the operation of consumer rights and market protection, and argues that each legal system has developed divergent means to attain the same goal. While some legal systems have organised sales with detailed rules, others have engaged in very limited market intervention; in the latter case, consumers are prevented from enjoying an important set of rights, as consumer rights and market protection are determined by the merchants.

Developing Internet Jurisdiction in B2B and B2C Contracts: Focusing on Iranian Legal System with Comparative Study of American, English and eu Laws

2017 ◽  
Vol 31 (3) ◽  
pp. 276-304
Author(s):  
Taher Habibzadeh
Keyword(s):  
Comparative Study ◽  
International Law ◽  
Consumer Protection ◽  
Legal System ◽  
American English ◽  
Computer Software ◽  
Modern World ◽  
Private International Law ◽  
Habitual Residence ◽  
Electronic Communications

Abstract In the modern world, electronic communications play a significant role in areas of national and international law such as Internet jurisdiction. Private international law provides that the competent court is the court within which jurisdiction the contract is performed, so it is important to know the place of performance of the contract in the case of contracts for digital goods such as e-books or computer software delivered online. It is equally important in the case of electronic services such as e-teaching. Furthermore, as consumer protection in B2C contracts is important in developing global e-commerce, it is important to consider whether the consumer party is able to bring an action against the business party in his own place of domicile or habitual residence. The article analyses these questions and proposes ways in which the Iranian legal system might be developed to address issues of Internet jurisdiction in B2B and B2C contracts.

CRIMINAL PROCEDURE IN CONTEMPORARY CHINA: SOCIALIST, CIVILIAN OR TRADITIONAL?

2010 ◽  
Vol 59 (4) ◽  
pp. 1099-1127 ◽  
Author(s):  
Bo Yin ◽  
Peter Duff
Keyword(s):  
Comparative Study ◽  
Legal System ◽  
Natural Science ◽  
Criminal Procedure ◽  
Comparative Law ◽  
Legal Systems ◽  
Legal Analysis ◽  
Methodological Tool ◽  
The Comparative Study ◽  
Analytical Device

Taxonomy, as a methodological tool introduced from natural science, brought the categorization of legal systems to comparative law.1The term ‘legal family’2is normally used as a metaphor, because it recognizes that within each grouping there are many variations. Each of the legal families is regarded as a combination of fundamental features of legal systems which have certain similarities. As an analytical device, taxonomy renders the comparison of different laws and legal institutions manageable by means of simplifying or abstracting the diverse and complicated realities of a myriad of legal systems. As a result, the concept of legal families acts as a support for legal borrowing and transplantation, as well as comprising an inevitable part of most comparative law works. Even where as few as two jurisdictions are involved, the categorization of legal families is still a useful tool for most comparative legal analysis. Assisted by the notion of legal families, comparativists can readily understand and explore an unfamiliar legal system.3Normally, such scholars tend to accept the conventional or widely accepted categorization of a particular legal system as belonging to a certain legal family. However, without detailed scrutiny of the first-hand material, distortions may arise as a result of preconceptions held at the beginning of the comparative study.4

scholarly journals Piercing the Corporate Veil and Ambiguities in the Iranian Legal System: A Comparative Study with California Law

2020 ◽  
Vol 13 (2) ◽  
pp. 209
Author(s):  
Ahmad Torabi
Keyword(s):  
Comparative Study ◽  
Legal System ◽  
Common Law ◽  
Law System ◽  
Iranian Law ◽  
System A ◽  
Commercial Code ◽  
Legal Challenges ◽  
The Common ◽  
Piercing The Corporate Veil

This paper focuses on the situation of doctrine of “piercing the corporate veil” in the current Iranian legal system especially in the Iranian Commercial Code and in the Iranian Civil Code. The author discusses the ambiguities and legal challenges which arise, directly or indirectly, from implementation of these challenges. There is also a comparative study of the doctrine with the common law system. The paper aims to highlight the defects of this doctrine in the Iranian law system and provides suggestions to improve it.

scholarly journals THE COMMITMENT OF CRUISE TOUR OPERATORS TO THE TOURIST SAFETY AND SECURITY IN THE ALGERIAN LAW (COMPARATIVE STUDY)

2021 ◽  
Vol 03 (06) ◽  
pp. 56-79
Author(s):  
Khouadjia Samiha HANENE
Keyword(s):  
Comparative Study ◽  
Legal System ◽  
Tourism Industry ◽  
Cruise Ship ◽  
Marine Tourism ◽  
Marine Transport ◽  
Passenger Ships ◽  
Residence Location ◽  
Responsibility System ◽  
Tour Operator

Marine transport has developed worldwide. As a result, the design of passenger ships has improved since they are considered the main residence location of passengers and tourists. Thus, ships have become floating hotels, where recreational activities, leisure and celebrations are found. This has turned cruise tours have into a lucrative business. Alongside the boom that marine tourism has witnessed as one of the most dynamic sectors in the tourism industry, tragic events, that cannot be ignored, took place. One of these events was the sinking of the Costa Concordia cruise ship in 2012 that caused many deaths and injuries among passengers and tourists on board. This event evokes the question of the responsibility of cruise tour operators, its range and its limits. In contrast with the Egyptian and French laws that distinguish between the responsibility system of the tour operator and that of the marine transporter, the Algerian law does not make any distinction between the two systems, resulting in legal shortcomings in the case of damage that affects tourists. This latter is subject to the marine transporter legal system concerning commitment and responsibility, where the damage must be in relation to the use of the ship, which implies that bodily and material damages are not included, resulting in the decrease in the protection expectation level of the tourist consumer. In addition to the above, the lack of a distinction between the two responsibility systems leads to the multiplication of law sources and to the difficulty of its legal characterization that helps in determining the responsibility of the professionals held responsible for the tourist safety and committed to their security.

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