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Abstract
This article considers the extent to which the nature of the regulation – tortious or criminal – influences the substantive content of the rules in England and France. It argues that the English and French regulatory features are the result of path dependence. Consequently, while they have led to substantive differences, they do not prevent the emergence of a shared approach to the wrong.
European Journal of Law Reform |
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Article | Commonalities in the English Tort and French Criminal Wrong of Defamation |
Keywords | defamation, tort, crime, comparative, path dependence |
Authors | Mathilde Groppo |
DOI | 10.5553/EJLR/138723702015017004004 |
Author's information |
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