Probleme ale Convenţiei Naţiunilor Unite asupra Contractelor de vânzare internaţională de mărfuri prin prisma Statelor nesemnatare
United Nations Convention Issues on Contracts for the International Sale of Goods from the perspective of non-signatory states

Summary/Abstract: Generally applauded as the most successful international trade treaty so far, The United Nations Convention on Contracts for the International Sale of Goods is law in 78 countries to date. CISG is the culmination of years of work spanning most of the 20th Century, representing compromises and solutions amenable to all legal systems whose representatives adopted the Convention. The scope of the Convention is limited to contract formation and the rights and obligations of the buyer and seller.However, this impressive number of states which join Convention’s regime has not resulted in an evenly-spread acceptance of the UN Convention worldwide. The scarcity of Convention-related case law from common law countries has led to the assumption that common law jurisdictions have specific issues with the application of the Convention.Although the U.K. and India actively participated in the Convention drafting process that started in the early 1970s, both have not ratified the Convention and no progress towards the accession has been made.This article seeks to provide a comprehensive critique of the similarity and differences of English and Indian law governing contracts for sale of goods and the United Nations Convention on Contracts for the International Sale of Goods. Moreover, the essay means to discuss the problems that may arise when UK and India ratify the UN Convention based on presenting main differences between English and India law and rules contained in the Convention.

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