There are two different types of legal academic scholarship that are needed to lay the foundations for the gradual development of a Europe-wide system of private law. On the one hand, it is necessary to write books, articles and case books that deal with their subject from a European standpoint and therefore represent the rules of national legal orders as merely local variations on a uniform European theme. An alternative approach is to develop, for certain fields of law, rules that are accepted in all European states. This latter approach is that of the Trento Project. Its particular strength lies in the fact that it selects specific conflicts of interest as its starting point and for each of these conflicts investigates whether they are resolved by the European legal systems in similar or different ways. From one example taken from contract law (the good faith clause) it is shown not only that differences may exist between the various European legal systems, but also why that should be so.
European Review of Private Law