Abstract
This article argues, first, that the rule of contra proferentem is not applicable to international sales contracts governed by the UN Convention on Contracts for the International Sale of Goods (CISG). Secondly, it argues that the common recognition of the rule of contra proferentem under the CISG is an instance of a broader phenomenon which it calls ‘internationality bias’. ‘Internationality bias’ is the tendency to project onto the provisions of a uniform private law instrument doctrines and concepts which are presumed to constitute universally recognised principles of private law or the ‘common core’ of various legal systems.
| Original language | English |
|---|---|
| Journal | International and Comparative Law Quarterly |
| Volume | 74 |
| Issue number | 1 |
| Publication status | Accepted/In press - 8 May 2025 |
Research Groups and Themes
- Centre for Private and Commercial law
- Centre for Global Law and Innovation
Keywords
- transnational commercial law
- uniform private law
- private international law
- internationality bias
- homeward trend
- UN Convention on Contracts for the International Sale of Goods
- CISG
- UNIDROIT Principles of International Commercial Contracts (PICC)
- contra proferentem
- contractual interpretation
- international sale of goods
- autonomous interpretation
