Unification, disintegration or optimization: purposes of modern sales law

Research output: Chapter in Book/Report/Conference proceedingChapterpeer-review


This chapter compares the fundamental purposes of domestic and international sales, to uncover expectations concerning their functions. It then explores biases in how each tends to be viewed in practice and outlines evidence which is often overlooked or cast aside regarding current usage of uniform sales law. Thereafter, the chapter explores both the so-called forces behind uniformity, and those which might hasten its disintegration. However, this dramatic juxtaposition is redefined in accordance with the arguably more pertinent question, that is, whether such forces enhance or detract from optimal or efficient choices of law, and the effect such forces might exert to aggravate or reduce market distortions. As part of this exploration, the chapter highlights some practical benefits of uniform law. The author challenges readers to re-evaluate their biases by questioning domestic law with the same vigour as is usually reserved for uniform law alone.
Original languageEnglish
Title of host publicationResearch handbook on international and comparative sale of goods law
EditorsDjakhongir Saidov
Place of PublicationCheltenham, UK ; Northampton, USA
PublisherEdward Elgar Publishing
Number of pages32
ISBN (Electronic)9781786436153
ISBN (Print)9781786436146
Publication statusPublished - 2019
Externally publishedYes

Publication series

NameResearch Handbooks in Private and Commercial Law series
PublisherEdward Elgar


  • In-house counsel
  • contract law
  • choice of law
  • international sales transactions
  • domestic sales law
  • international sales law
  • transaction costs


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