International Encyclopedia of Comparative Law Online

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I. Overview
(621 words)

Volume VII: Contracts in General | Chapter 7 (2006): Contract Law of Islam and the Arab Middle East

Completed in September 1997

Frank E. Vogel

1. Two systems of contract law. – This contribution examines two systems of contract law, that of islamic law (sharī c a) and that of contemporary arab nations. In one sense these two systems are worlds apart: the authoritative form of one is both medieval and rooted in religion, while the other is contemporary, usually positive and secular, and influenced by modern western laws, mainly those of france. In other respects, however, these two syst…

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Frank E. Vogel, “I. Overview”, in: International Encyclopedia of Comparative Law Online, Edited by: U. Drobnig, R. David, H. H. Egawa, R. Graveson, V. Knapp, A. T. Von Mehren, Y. Noda, S. Rozmaryn, V. M. Tschchikvadze, H. Valladão, H. Yntema, K. Zweigert. Consulted online on 31 May 2023 <>
First published online: 2018

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