The advents of uniform international commercial laws and model laws have seen serious variations in the applications and interpretations of different doctrines. The doctrine of impossibility of performance of a contract has spawned different routes via the connotations and interpretations various legal systems and regimes of laws have given to it. This article will constructively and critically analyse the doctrines of exemption, force majeure and frustration under the CISG, UNIDROIT Principles and English law respectively in order to lay the foundation for further and better appreciation of these doctrines.
Business Law Review