While English Lawyers Say No, Civil Lawyers Say Yes. The Intriguing Case of Frustration of Purpose in Comparative Law - European Review of Private Law View While English Lawyers Say No, Civil Lawyers Say Yes. The Intriguing Case of Frustration of Purpose in Comparative Law by - European Review of Private Law While English Lawyers Say No, Civil Lawyers Say Yes. The Intriguing Case of Frustration of Purpose in Comparative Law 31 5

A curiosity in comparative law is found in the doctrine of frustration of purpose, created by the English courts in 1903, which never took flight and remained a rarity of exceptional application, but at the same time, it was looked upon favorably by certain civil lawyers – especially Latin-Americans – who defended the importation of frustration of purpose with urgency. This paper explains that frustration of purpose is unnecessary and redundant for Civil Law jurisdictions.

European Review of Private Law