CISG DEUTSCH ENGLISH PDF

Ratified by 93 countries, known as "Contracting States", the Convention governs a significant proportion of world trade , making it one of the most successful instruments of international trade law. Guatemala and Laos are the most recent parties to the Convention, acceding to it on 12 December and 24 September , respectively. To that end, it establishes substantive rules that regulate the duties and obligations of both parties, including the delivery of goods, contract formation, and remedies for breach of contract. The CISG is considered among the greatest successes of UNCITRAL, and is regarded as the "most successful international document" in unified international sales law, [10] [11] since its parties represent "every geographical region, every stage of economic development and every major legal, social and economic system". Vis International Commercial Arbitration Moot , one of the largest and most prominent international moot court competitions in the world. As of 27 September , the following 92 states have ratified, acceded to, approved, accepted, or succeeded to the Convention: [14].

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The intent is to present each official text and texts of the CISG in each of the languages into which it has been translated. Roy M. Goode notes "the extreme difficulty not only in translating concepts that have no exact legal equivalent in the other system, but also in converting the structure and syntax of one language into the quite different structure of another.

This wording represents the direct, "frozen" will of the legislature and must be followed by all courts by virtue of its supremacy under the separation of powers. Although multilingual conventions support their own international acceptance, and present valuable advantages for parties from different countries that enter a contract, there is also the side-effect of a vast amount of possible interpretations. A stringent presumption exists in favor of that text which an "international legislator" declared authentic as a representation of the legislator's actual will concerning the grammatical meaning of the text's wording.

All texts that are not authentic are excluded from an autonomous interpretation. The only texts that have become binding on the court by way of a ratification of the Convention are those that were declared authentic by the "international legislator.

As the "international legislator" declares, since all these languages are equally authentic, no language may prevail. A lawyer must find the accurate text "texte juste" by comparing them all. Such an analysis reveals that concerning the CISG, the official but non-authentic German translation that was jointly drafted by Austria, the Federal Republic of Germany, the former German Democratic Republic and Switzerland has to be ruled out as the basis for an autonomous interpretation.

As such, it is reasonable to examine the English and French texts of the CISG to find a texte juste, because these were the languages in which the deliberations and legal negotiations among the representatives of the Contracting States took place.

In the Judgement of August 30th, , on the Mavrommatis Palestine Concessions, the International Court of Justice states that "Where two versions possessing equal authority exist [a tribunal] is bound to adopt the [version which is] in accordance with the common intention of the Parties" A Digest of the decisions of the International Court, vol 1, ed. Marek The Hague: Martinus Nijhoff By calling for "the meaning which best reconciles the text, having regard to the object and purposes of the treaty", article 33 of the Vienna Convention on the Law of Treaties seeks to aid the resolution of discrepancies in official texts.

However, because one can encounter translated words that have different meanings which are difficult to reconcile, parties may wish to include in their contract a Language Clause, for example, "The applicable text of the Convention shall be the official United Nations text in the language in which this contract is written. Programs at Pace. Albanian texts text as published in the Official Bulletin of The Republic of Albania see also text coordinated by Prof.

Friehe Armenian text text coordinated by Prof. Friehe Bulgarian text text coordinated by Prof. Friehe Croatian text text coordinated by Prof. Friehe Danish texts text provided by the Faculty of Law of the University of Copenhagen see also text coordinated by Prof. Friehe Estonian text text coordinated by Prof.

Friehe Georgian text text coordinated by Prof. Friehe German text text coordinated by Prof. Friehe Greek text text coordinated by Prof. Friehe and Soterios Loizou Hebrew text text coordinated by Prof. Friehe Hungarian text text coordinated by Prof. Friehe Italian texts text provided courtesy of Giovanna Micheli see also text coordinated by Prof.

Friehe Korean text text coordinated by Prof. Friehe Latvian text text coordinated by Prof. Friehe Lithuanian text text coordinated by Prof. Friehe Macedonian text text coordinated by Prof. Friehe Moldavian text text coordinated by Prof. Friehe Mongolian text text coordinated by Prof. Friehe Norwegian texts text as published by the Justisdepartementet of Norway; entered on the Internet by Lovdata, Norway's law database see also text coordinated by Prof.

Friehe Polish texts text accessed from Dziennik Ustaw No. Friehe Romanian text text coordinated by Prof. Friehe Slovakian text text coordinated by Prof. Friehe Slovenian texts text provided by the Chamber of Commerce and Industry of Slovenia see also text coordinated by Prof. Friehe Swedish text text coordinated by Prof. Friehe Ukrainian text text coordinated by Prof. Challenges present Tristan Laflamme states: "An abundance of this sort may provoke two contradictory situations.

On one side, it may prove helpful to look at the different wordings in order to solve ambiguities. In this perspective, each text contributes to the construction of the others and clarifies the intention of the Contracting States.

Similarly, Amy H. Kastely states: "[W]ords used in one language. The terms 'offer' and "acceptance" provide powerful examples of this. In English these words carry a rich heritage of legal doctrine, and their equivalents in the Western European languages have similar depth. Yet the translations of these words used in the other official versions, such as Chinese and Arabic, do not carry similar implications.

Int'l L. Frank Diedrich states: "[W]hen interpreting multilingual conventions, there is an issue as to which language of the text is authentic, since the starting point for any statutory interpretation is logically the wording of the statute itself. Id at 8. Contract solution recommended By calling for "the meaning which best reconciles the text, having regard to the object and purposes of the treaty", article 33 of the Vienna Convention on the Law of Treaties seeks to aid the resolution of discrepancies in official texts.

Institute of International Commercial Law. About the Institute. Members of the Institute. Remembering Albert H. Other Programs. Alternative Dispute Resolution Programs. Willem C.

Vis International Commercial Arbitration Moot. Archived Lectures and Conferences. Lexical Initiative for International Commerce. Clive M. Schmitthoff Essay Competition. Institute News and Events.

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