European Causation in Tort Law: a Comparative Study with emphasis on Medical Law in the United Kingdom, Germany and France and Luxembourg

This purpose of this paper is to explore how the different jurisdictions under consideration here treat the legal notion of causation. These jurisdictions are the United Kingdom, Germany and France and Luxembourg. The problem of causation has been described as insoluble and I shall not be trying to solve it. Rather I shall consider how each of the jurisdictions here treats causation in the law, the better to ascertain whether there can be any common European idea of causation in this field. The reason for this is not only as two of the European projects aiming at codification in tort law seek... Mehr ...