European Journal of Law Reform

Article

Commonalities in the English Tort and French Criminal Wrong of Defamation

Keywords defamation, tort, crime, comparative, path dependence
Authors Mathilde Groppo
Author's information

253267 Mathilde Groppo
PhD Candidate, King’s College London.
  • 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.

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