Right to Avoid International Sales Contracts: CISG & OHADA compared.

      Аннотация: Doing business in Africa can pose practical challenges to foreign businesses and their lawyers. Apart from the institutional loopholes that could easily be identified within the African business environment, the laws themselves could equally be problematic. The challenge of understanding the context of African business laws such as the OHADA sales law (which maintains a deep rooted connection with French domestic laws) vis-?-vis a more familiar and relatively sucessful uniform sales law such as the Vienna Convention on Contracts for the International Sale of Goods(CISG)inspired this book by Mana Tita. The avoidance or termination of sale of goods contracts typifies the sort of legal problems businesses are bound to face in Africa. So, from a comparative approach, this research endeavor seeks to open the doors of an unassessed academic and practical question on the new OHADA sales law approach on the right of avoidance in comparison to the CISG. Academics and practitioners shall be inspired to re-examine the position of the OHADA sales law as far as the right of avoidance is concerned and to pinpoint the effects it poses on international trade in the African continent.

Ключевые слова: CISG, comparative study, Contracts, Avoidance/termination, international sale of goods, OHADA Uniform Act