Uprawnienie poszkodowanego w wypadku komunikacyjnym do pojazdu zastępczego – ujęcie prawnoporównawcze
The right of the aggrieved party in a motor accident to receive a substitute car – legal and comparative analysis

Summary/Abstract: The purpose of this article is to discuss the problem of reimbursing the substitute vehicle rental costs in the case law and insurance practice in European countries (i.e. the European Economic Area, including Germany, France, Sweden, the UK and even Iceland) as well as the US and Canada. The article presents rulings of courts in foreign states and focuses on circum- stances taken into account by insurers (and authorities responsible for applying the law) when resolving matters related to substitute car rental or reimbursement of the rental costs. The article closes with the author's conclusions that it is difficult to talk about any unified practice – as far as foreign states are concerned – with regard to reimbursement of substi- tute car rental costs.

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