COMPARATIVE ANALYSIS OF CONTRACT LAW BETWEEN THE REPUBLIC OF UZBEKISTAN AND GERMANY
DOI :
https://doi.org/10.5281/zenodo.18227486Résumé
This article provides a comparative legal analysis of the legislation of the Republic of Uzbekistan and the Federal Republic of Germany in the field of conclusion and termination of contracts. The study examines the concept of a contract, the principle of freedom of contract, types of contracts, the procedure for concluding contracts, their form, mandatory conclusion of contracts, as well as the grounds and procedure for modification and termination of contracts. The analysis is based on the provisions of the Civil Code of the Republic of Uzbekistan and the German Civil Code (BGB). The results of the comparative study demonstrate that German contract law contains more flexible mechanisms for regulating contractual relations, while the contract law of Uzbekistan is gradually harmonizing with international and European legal standards. The article has scientific and practical significance for improving contract law and applying foreign legal experience in national legislation.
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