Comparative and Critical Analysis of the Doctrine of Exemption/Frustration/Force Majeure under the United Nations Convention on the Contract for International Sale of Goods, English Law and UNIDROIT Principles

The English Law Impossibility Perspective in the Terminologies Could not reasonably be expected to have avoided or overcome it or its consequences Exemption and burden of proof under article 79 of the CISG Without fault of the parties Agreement to sell specific goods Background Passing of Risk and Frustration under s 20 of 1979 Act Elements of avoidance under the CISG Elements of termination under the UNIDROIT Principles