International Trade Law Research Paper 2022

Running head: INTERNATIONAL TRADE LAW
International Trade Law
Name of the Student
Name of the University
Author Note

1INTERNATIONAL TRADE LAW
Introduction
The abidance of the obligations arising out of the contract is a general principle that the
buyer or a seller has an obligation to ensure in any form of contract. Hence, it can be
construed that both the seller and the buyer are under an obligation to carry out their
contractual duties. Any breach of such contractual duties would lead to a breach of the
contract1. For instance, there may be of failure on the part of the seller in making delivery of
the good sold to the buyer on time for the purpose of complying with the standards that has
been previously determined in the agreement effecting the sale. Again, there are certain
instances where the buyer makes a default in in making payment with respect to the cost of
the goods2. This is the general rule for the law of contract that any discrepancy that might
arise with respect to the performance of the contract on the part of any of the parties, the
same would result in the right being created for the aggrieved party to claim damages as well
as remedies from the other party whose contractual breach has resulted in such an injury. All
the contracts that have been created between two parties for effecting a sale in relation to
goods will be governed by the terms of the contract entered upon3. All the obligations,
remedies and other conditions relating to the contract are required to be carried out as per the
conditions provided in the contract. However, there are certain cases, where the contract fails
to cover all the aspect regarding the obligations remedies and other conditions that are
required to be complied with while performing the contract. These instances crops up, when
the parties to the contract fails determine all the rights and duties that they have been agreeing
to undertake under the contract at the time of instituting the contract. In such cases, the rights
and obligations arising out of the contract in a particular sale of goods need to be governed by
1 Knapp, Charles L., Nathan M. Crystal, and Harry G. Prince. Problems in Contract Law: cases and materials.
Aspen Publishers, 2019.
2 Stone, Richard, and James Devenney. The modern law of contract. Routledge, 2017.
3 Lookofsky, Joseph. Understanding the CISG:(Worldwide) Edition. Kluwer Law International BV, 2017.

2INTERNATIONAL TRADE LAW
the law of contract4. The remedies that are ensured to a buyer of goods in relation to the
breach that has been caused by the seller in a contract for sale of goods may vary with respect
to the jurisdiction followed. The remedies provided for the breach of contract in a sale of
goods agreement are more elaborately stated in the UN Convention on Contract for the
International Sale of Goods (CSIG) when contrasted with the Sale of Goods Act 1979 (SGA)
under the English law. In case of CSIG, the scope of remedies provided to a buyer is wider
and me include additional time, specific performance as well as reduction in the price. Again,
the remedies that are available to all buyer under the SGA, are limited and extend only up to
termination as well as damages5.
This paper will strive to analyse the remedies that are available to a buyer under the CISG.
It will also strive to analyse the remedies that are available to a buyer under the contract for
sale of goods as per the provisions of SGA. This paper would differentiate between the
remedies available under both the legislations in relation to the sale of goods.
Discussion
The CSIG has a crucial role in the international trade. Several jurisdictions has ratified this
convention for being applied in the international seals of these jurisdictions. The laws
prevailing in England and Wales in relation to the international sale of goods has been
governed by the SGA as well as the common law. In various instances, there has been a
proposal presented for the purpose of ratification of CSIG into the jurisdiction of England and
Wales. However, the two laws offer very different approaches in relation to the remedies that
are available under the international sale of goods. Both the jurisdictions have separate
approaches in relation to the specific performance, repudiation of the contract, price reduction
4 Lookofsky, Joseph. Understanding the CISG:(Worldwide) Edition. Kluwer Law International BV, 2017.
5 Gillette, Clayton P., and Steven D. Walt. The UN Convention on contracts for the international sale of goods:
theory and practice. Cambridge University Press, 2016.

3INTERNATIONAL TRADE LAW
as well as the right relating to cure6. For this purpose, the first remedy that can be discussed
upon based on both the regimes is the specific performance right that has been conferred
upon a buyer whose rights in relation to a contract for sale of goods has been infringed upon.
In discussing the same, the chief concern is the usefulness of the specific performance
remedy provided by the CSIG in comparison to the same remedy provided by the SGA.
Article 46 of the CSIG, provides for the remedy available to a buyer in the form of specific
performance in case of any breach of the contractual obligations in relation to the
international agreement for sale of goods7. Under this article, the buyer is justified in
requiring performance from the seller in relation to his contractual obligations. However, this
remedy will not be available to the buyer is he has been visited to any e remedy which does
not seems to be consistent with the requirement of this article. In the event of the goods
supplied by the seller not matching with the descriptions of the contract for the sale of goods,
the buyer has the option of compelling the seller to deliver substitute goods. However, such a
right would only be available to the buyer, if the goods that has been delivered contains
inadequacies or defects that has the probability of defeating the mean objective of the
contract for the sale of goods8. In such a case, the buyer has the right to issue a notice
requesting the substitution of the goods. This notice can be issued in compliance with the
requirement provided under article 39. Such a notice needs to be issued within a time, which
appears to be reasonable. The buyer has also the option of claiming repair to be done upon
the goods, in case of the goods being deviant from the description that has been mentioned in
the agreement for effecting the sale of the goods. However, this remedy will only be available
to a buyer if it can be ensured that such a remedy would be reasonable based on the
6 Janssen, André, and Navin G. Ahuja. "Bridging the gap: The CISG as a Successful Legal Hybrid between
Common Law and Civil Law?." Uniform Rules for European Contract Law?: A Critical Assessment. Hart
Publishing, 2018. 137-162.
7 Wu, Xiyuan. "The Mitigation Rule and Impacts of Overdue Payments in International Business." (2018).
8 Mai, Nan Kham. Exclusion and Limitation of Liability for Non-conformity of Goods: A Comparative Study on
CISG, UCC and UK Law. Diss. Niigata University, 2017.

4INTERNATIONAL TRADE LAW
circumstances of the case. However, such request in relation to repair can only be meat in
compliance with article 39 of the CISG9.
The CSIG confers the right upon the parties to exclude the entire or any part of the
convention. Under the CSIG, principle of freedom of the parties to form their own contractual
obligations has been extended. Article 46 has an obligation only with respect to areas where
the parties have failed to choose any other remedy. This article provides a remedy to the
buyer in the event of a failure on the part of the seller to ensure the performance of the
obligations arising out of the sale of goods contract. And this article, the CSIG requires the
seller a specific performance as a remedy for the buyer for such a breach of the contract for
sale of goods10. This right has been conferred upon the buyer and is activated automatically
upon the causing of the breach by the seller. This right does not require the discretion of the
court as it implies an automatic right. However this right will only be available to the buyer if
he has not taken resort under any other remedies provided by the CISG other than the one
provided under article 46. In case the buyer has revealed a remedy of avoidance of contract,
which is available only in case of a breach of the fundamental object of the contract, he
would not be able to seek resort under article 46 for requiring the seller specific
performance11. There are instances where the seller fails to deliver goods, which matches the
description contained in the contract for the sale of goods. In such a case, the seller has the
entitlement of claiming remedy in two ways. Firstly, the buyer has the option of claiming
substitute goods to be delivered, which complies with the description of the goods contained
in the contract for sale of goods. Secondly, the buyer is also conferred with the entitlement to
claim a repair to be carried out with respect to the goods that failed to match with the
9 Loschi, Riccardo. "Opportunistic Exercise of Termination Rights: the Commodity Trade Case-An Analysis of
English Contract Law and the CISG." Bocconi Legal Papers 9 (2017): 39.
10 Ahmed, Bzhar Abdullah, and Hassan Hustafa Hussein. "Avoidance of Contract as a Remedy under CISG and
SGA: Comparative Analysis." JL Pol'y & Globalization 61 (2017): 126.
11 Hayward, Benjamin, Bruno Zeller, and Camilla Baasch Andersen. "The CISG and the United Kingdom—
Exploring Coherency and Private International Law." International & Comparative Law Quarterly 67.3 (2018):
607-641.

5INTERNATIONAL TRADE LAW
description of the contract of sales of goods, to make it comply to the terms of the contract
for sale of goods12. A buyer has the option of availing any of the remedies. However, for the
purpose of deciding among these remedies, consideration need to be given to the
circumstances of the case and the extent to which the goods fails to comply with the
description. The buyer has the option of availing any of the remedies13.
A buyer is also conferred with the right under article 74 to claim damages for the
discrepancies and inadequacies that existed in the supply of goods made by the seller. In
cases where the goods are already paid for, the buyer has the option of claiming a refund. In
case the buyer has succeeded in in establishing the inadequacies in the goods supplied, he
may claim the return of the payment he has made under the contract for sale of goods. The
buyer also has the option of claiming any interest or profit that has been lost by him by virtue
of the failure to comply with the contract for sale from the seller14. This article also entitles
the buyer to claim any other damages that might be appropriate in the given circumstances.
However, any buyer who has been availing remedy under article 74 does not have the option
of availing remedy of specific performance. This is because a single remedy can be availed
for a single breach of the contract for sale of goods. Once the buyer claims a refund and has
been successful in availing the same, he will not be entitled to claim specific performance
against the seller. He will also not be able to recover any repairs with respect to the goods if
he has claim the money back that he has paid with respect to the goods in question15. Again,
under article 49, in case the buyer has been aggrieved by the delivery of inadequate goods by
the seller, he will be entitled with the alternative of repudiating the contract for the sale of
12 Mai, Nan Kham. "Legal Remedies for Non-conformity of Goods under CISG, UCC and UK Law." (2016).
13 Zareshahi, Ali. "A Comparative Study of Damages and Price Reduction Remedy for Breach of Sale Contract
under CISG, English and Iranian Laws." J. Pol. & L. 9 (2016): 126.
14 Singh, Lachmi. The United Nation Convention on Contracts for the International Sales of Goods 1980 (CISG)
An examination of the buyer’s remedy of avoidance under the CISG: How is the remedy interpreted, exercised
and what are the consequences of avoidance?. Diss. University of the West of England, 2015.
15 Schwenzer, Ingeborg, and Ilka Beimel. "Replacement and Repair of Non-Conforming Goods under the
CISG." Internationales Handelsrecht 17.5 (2017): 185.

6INTERNATIONAL TRADE LAW
goods. However, in case such a breach on the part of the seller and avoidance as a
consequence of the same has caused any loss of profit or interest to the buyer, he will have
the option of claiming damages for the same. This will be available to him even if he has
availed for a remedy on the article 4616. The claiming of damages for loss of profits or
interest does not have any connection with the claim of damages as a refund for the payment
made with respect to the goods. The claim for damages for loss of profits or interests will be
available to a buyer in case of both specific performance availed by the buyer as well as
refund claims by the buyer. Any of these two remedies will not have the effect of restricting
the claim for loss of profit or interest by the buyer17.
The primary remedy that has been provided by the CISG in relation to the breach of the
seller to meet the obligation of the contract for the sale of goods by the delivery of goods
which does not matches the description of the contract is specific performance18. However,
there are several concerns regarding the justification given under the CISG in relation to
conferring open the specific performance, the status of a primary remedy. There are two
contentions presented by the several scholarly opinions regarding the remedy that needs to be
availed by a buyer with respect to a breach of the contract for sale of goods19. According to
certain opinion, the specific performance would be more appropriate. This contention has
been based upon the fact that it is a general principle to carry out the obligations created by
virtue of a contract. On the other hand, there are certain opinion that agrees that the claim for
damages is more appropriate as certain goods cannot be substituted with another. In such a
case, a payment of damages will be more viable and desirable20.
16 Munoz, Edgardo, and David Obey Ament-Guemez. "Calculation of Damage on the Basis of the Breaching
Party's Profits under the CISG." Geo. Mason J. Int'l Com. L. 8 (2016): 201.
17 Martin, Jennifer S. "Private Law Remedies, Human Rights, and Supply Contracts." Am. UL Rev. 68 (2018):
1781.
18 Saunders, Kurt M., and Leonard Rymsza. "Contract Formation and Performance Under the UCC and CISG: A
Comparative Case Study." J. Legal Stud. Educ. 32 (2015): 1.
19 Hassan, Amer Mohammed Ali. "THE SELLER’S RIGHT TO CURE AND FUNDAMENTAL BREACH
UNDER CISG." University of Thi-Qar Journal of Law Research 9.15 (2017): 416-436.
20 Schwenzer, Ingeborg. "The CISG–A fair balance of the interests of the seller and the buyer." (2016): 79-91.

7INTERNATIONAL TRADE LAW
There is yet another opinion under which the specific performance in relation to
contractual breach has been required to be refrained from being resorted to. This is because
the enforcement of the specific performance would require more costs and time. Moreover,
the awarding of damages is expected to suffice and is appropriate for the breach of the
contract caused to the buyer. The enforcement of the specific performance of the contractual
obligations by way of replacement or repair may not always result in the grievances of the
buyer being addressed and resolved. This contention can be supported by the fact that there is
no guarantee that the repairs will result in the desirable outcome21. Moreover, the replacement
that will be provided under this remedy may also amount to the delivery of another faulty
goods. Again, the loss that has been caused to the buyer for the breach of the contractual
obligations by way of delivery of goods not confirming with the description of the contract
may have resulted in several ways. The buyer may have also suffered certain injuries relating
to the loss of profits or loss of interests by virtue of searcher delivery of goods not in
conformity with the description contained in the agreement for the sale of such goods22. This
requires a choice to be provided to the buyer in relation to the remedy he is needed to be
extended with in relation to the particular goods in question. The choice will be based on the
circumstances of the case. The situation of the buyer needs to be considered while making a
decision in that furtherance. However, the awarding of the damages may also suffice in most
of the cases and in the light of this contention, it can be stated that the question of
replacement for repairs does not arise. Again, from the usual sense of the international trade,
it can be stated that the only awarding of damages will not be sufficient for the purpose of
rendering a compensation to be appropriate23. The buyer may require the goods and the goods
may not be e available in the market. In case of certain specific goods that cannot be availed
21 Ramesh, Aditi, Petra Ghicu, and Cara Putman. "CISG v. UCC: Key distinctions and applications." The
Business & Management Review 7.5 (2016): 459.
22 Schwenzer, Ingeborg. "Ethical standards in CISG contracts." Uniform Law Review 22.1 (2017): 122-131.
23 Agapiou, Nevi. Buyer’s remedies under the CISG and English sales law: a comparative analysis. Diss. School
of Law, 2015.

8INTERNATIONAL TRADE LAW
easily, the remedy of compensation will not suffice. In such an instance, the specific goods
that has been contracted for is a necessity for the buyer. The repair and replacement of such
goods are required for the purpose of providing appropriate remedy to the buyer. Although
the availing of the remedy has been a primary rights of the buyer and he has the option of
choosing between the remedy that he wanted for a particular situation, but in case of
monetary compensation the amount of losses that needs to be awarded to the buyer will
depend upon the discretion of the court24. While exercising such a discretion, the court needs
to consider the circumstances of the case for the purpose of estimating the compensation that
need to be awarded. However, the choice between compensation and replacement or repair
will depend upon the discretion of the buyer. In case the buyer has not been fairly
compensated by way of repair and replacement, he may also require a compensation for the
loss of profits or interest along with such a remedy of replacement25.
Again, under the SGA, a buyer may be conferred with the right to damages as well as to
enforce specific performance in case any of his rights has been violated. Under the provisions
contained in section 51, for every non delivery that has been committed by the seller, the
buyer will be conferred with the right to claim damages against the seller. For the purpose of
claiming such damages, the buyer needs to establish that the seller has neglected or has
refused to make delivery of the goods in a wrongful manner. Such damages can be claimed
by way of bringing an action in front of the court and the action is to be instituted by the
buyer26. For the purpose of computing the quantum of damages that needs to be awarded to
the buyer owing to the breach, the court will consider and estimate only those losses which
results naturally as well as directly from the usual course of dealings. A loss that has a remote
proximity with the non delivery made by the seller will not be included in the estimation of
24 Muñoz, Edgardo. "Teaching comparaTive conTracT Law Through The ciSg." Indon. J. Int'l & Comp. L. 4
(2017): 725.
25 Bridge, Michael. "Remedies and damages." International Sales Law. Nomos Verlagsgesellschaft mbH & Co.
KG, 2016.
26 Mai, Nan Kham. "Non-Conformity of Goods and Limitation Clause under CISG, UCC and UK Law." (2015).

9INTERNATIONAL TRADE LAW
damages by the court. In case of a market being available for the goods, the measure of the
damages needs to be based upon the difference that can be derived from deducting the
contract price from the market price from the current price27. This is because the contract
price depicts the price that the person has agreed to sacrifice for the purpose of availing such
goods. The increase in the market price afterwards depicts the profit that the buyer could have
made, if the goods has been delivered to him on time. For the purpose of the delay in the
delivery of the goods or a failure on the part of the seller to deliver the goods will deprive the
buyer from availing such a profit. The ascertainment of the damage would the based upon the
difference of the prices28. Again, under the provisions contained in section 52, the buyers
conferred with the right to info specific performance of the contract for sale of goods. In the
event of any breach committed by the seller in relation to the contract for the sale of goods by
way of non delivery or delivery not fitting the description of the contract, the buyer would
have the option of bringing an action in front of the court to enforce performance. On being
satisfied with the claims brought buyer against the seller on the basis of non delivery of
specified goods, the court may order for the performance of the contract for the sale of such
goods29. In such a case the court may also deprive the defendant of the option of retainment
of the goods open the payment of required damages. As per the provisions contained under
the section 53, the court may also award damages to the buyer against the seller in case the
seller has made a contravention in relation to a condition contained under the contract of sale
of goods. Such contravention needs to be referred to as a breach of warranty. This depicts a
breach with respect to the description of the goods that was required to be delivered on the
contract for the sale of the goods. In such a case, the court may order for remedy as it may
deem to be fit under a given set of circumstances30.
27 Bridge, Michael G. The international sale of goods. Oxford University Press, 2017.
28 Beheshti, Reza. "A comparative and normative analysis of the remoteness test in the availability of significant
remedies in international sales transactions." Journal of Business Law 5 (2016): 289-310.
29 Goldberg, Victor P. "The Lost Volume Seller in English Law." Columbia Law and Economics Working Paper
594 (2018).
30 Marsh, Peter. "Contract law." Contracting for Project Management. Routledge, 2017. 65-80.

10INTERNATIONAL TRADE LAW
There has been a necessity for the purpose of drawing a distinction between the remedies
provided to a buyer under the English law as well as under the provisions of CISG. With
respect to the enforcement of specific performance, the scope under the English law is
narrower and that of its coop under the CISG. The remedy of specific performance is
available under the SGA in a very e limited number of circumstances. The enforcement of the
same depends upon the discretion of the courts and the courts are not very liberal with the
same. On the other hand, under CISG, the buyer is conferred with the right to make a choice
of the remedy he wants to avail31. Moreover, the chances of being awarded with the
enforcement of specific performance under CISG is more likely then that of the awarding of
damages. However, in case a buyer has availed a remedy of repudiation of the contract for the
sale of goods, he will not be entitled to claim any of the damages or enforce the right of
specific performance. However, under the provisions of CISG, the buyer may both repudiate
the contract for the sale of goods as well as claim damages that has been caused to him owing
to the breach. Again, under SGA, the buyer cannot avail specific performance as well as
damages together32. He would be awarded with any of them and the choice would be lying
with the discretion of the court. In such a case, the chances of awarding specific performance
are much less compared to the award for damages. However, in case of CISG, the discretion
belongs to the buyer to choose between specific performance or damages. In certain cases,
the buyer is also entitled to claim both specific performance as well as damages. Hence,
under English law, the court has the discretion to award a specific performance and the buyer
does not have a choice. On the other hand, CISG confers the right upon the buyer to make a
choice for the purpose of availing specific performance33. Moreover, the provisions of SGA
provides for certain principal that needs to be strictly adhered to while computing the
31 Maier-Lohmann, Till. "Buyer’s self-repair of non-conforming goods versus seller’s right to cure under Article
48 of the CISG." Uniform Law Review 24.1 (2019): 58-72.
32 Butler, Petra. "Introduction to Articles 45–65 CISG." Commercial Law. Nomos Verlagsgesellschaft mbH &
Co. KG, 2018.
33 Brand, Ronald A. "The CISG: Applicable Law and Applicable Forums." Journal of Law and Commerce 38
(2019).

11INTERNATIONAL TRADE LAW
damages to be awarded to a certain buyer. However, under CISG the computation of the
damages to be awarded depends upon the circumstances of the case and no hard and fast rule
has been provided for the purpose of the same34.
Conclusion
Hence, it can be concluded that CSIG has been playing an important part in the
international trade. Several jurisdictions has ratified this convention for being applied in the
international seals of these jurisdictions. The laws prevailing in England and Wales in
relation to the international sale of goods has been governed by the SGA as well as the
common law. In various instances, there has been a proposal presented for the purpose of
ratification of CSIG into the jurisdiction of England and Wales. However, the two laws offer
very different approaches in relation to the remedies that are available under the international
sale of goods. With respect to the enforcement of specific performance, the scope under the
English law is narrower and that of its coop under the CISG. The remedy of specific
performance is available under the SGA in a very e limited number of circumstances. The
enforcement of the same depends upon the discretion of the courts and the courts are not very
liberal with the same. On the other hand, under CISG, the buyer is conferred with the right to
make a choice of the remedy he wants to avail35. Moreover, the chances of being awarded
with the enforcement of specific performance under CISG is more likely then that of the
awarding of damages. However, in case a buyer has availed a remedy of repudiation of the
contract for the sale of goods, he will not be entitled to claim any of the damages or enforce
the right of specific performance. Again, under SGA, the buyer cannot avail specific
performance as well as damages together . He would be awarded with any of them and the
choice would be lying with the discretion of the court. In such a case, the chances of
34 Eiselen, Sieg. "Scope of CISG." International Sales Law. Nomos Verlagsgesellschaft mbH & Co. KG, 2016.
35 Maier-Lohmann, Till. "Buyer’s self-repair of non-conforming goods versus seller’s right to cure under Article
48 of the CISG." Uniform Law Review 24.1 (2019): 58-72.

12INTERNATIONAL TRADE LAW
awarding specific performance are much less compared to the award for damages. However,
in case of CISG, the discretion belongs to the buyer to choose between specific performance
or damages. In certain cases, the buyer is also entitled to claim both specific performance as
well as damages. Hence, under English law, the court has the discretion to award a specific
performance and the buyer does not have a choice. On the other hand, CISG confers the right
upon the buyer to make a choice for the purpose of availing specific performance.

13INTERNATIONAL TRADE LAW
References
Agapiou, Nevi. Buyer’s remedies under the CISG and English sales law: a comparative
analysis. Diss. School of Law, 2015.
Ahmed, Bzhar Abdullah, and Hassan Hustafa Hussein. "Avoidance of Contract as a Remedy
under CISG and SGA: Comparative Analysis." JL Pol'y & Globalization 61 (2017): 126.
Beheshti, Reza. "A comparative and normative analysis of the remoteness test in the
availability of significant remedies in international sales transactions." Journal of Business
Law 5 (2016): 289-310.
Brand, Ronald A. "The CISG: Applicable Law and Applicable Forums." Journal of Law and
Commerce 38 (2019).
Bridge, Michael G. The international sale of goods. Oxford University Press, 2017.
Bridge, Michael. "Remedies and damages." International Sales Law. Nomos
Verlagsgesellschaft mbH & Co. KG, 2016.
Butler, Petra. "Introduction to Articles 45–65 CISG." Commercial Law. Nomos
Verlagsgesellschaft mbH & Co. KG, 2018.
Eiselen, Sieg. "Scope of CISG." International Sales Law. Nomos Verlagsgesellschaft mbH &
Co. KG, 2016.
Gillette, Clayton P., and Steven D. Walt. The UN Convention on contracts for the
international sale of goods: theory and practice. Cambridge University Press, 2016.

14INTERNATIONAL TRADE LAW
Hayward, Benjamin, Bruno Zeller, and Camilla Baasch Andersen. "The CISG and the United
Kingdom—Exploring Coherency and Private International Law." International &
Comparative Law Quarterly 67.3 (2018): 607-641.
Janssen, André, and Navin G. Ahuja. "Bridging the gap: The CISG as a Successful Legal
Hybrid between Common Law and Civil Law?." Uniform Rules for European Contract
Law?: A Critical Assessment. Hart Publishing, 2018. 137-162.
Knapp, Charles L., Nathan M. Crystal, and Harry G. Prince. Problems in Contract Law: cases
and materials. Aspen Publishers, 2019.
Lookofsky, Joseph. Understanding the CISG:(Worldwide) Edition. Kluwer Law International
BV, 2017.
Lookofsky, Joseph. Understanding the CISG:(Worldwide) Edition. Kluwer Law International
BV, 2017.
Loschi, Riccardo. "Opportunistic Exercise of Termination Rights: the Commodity Trade
Case-An Analysis of English Contract Law and the CISG." Bocconi Legal Papers 9 (2017):
39.
Mai, Nan Kham. "Legal Remedies for Non-conformity of Goods under CISG, UCC and UK
Law." (2016).
Mai, Nan Kham. "Non-Conformity of Goods and Limitation Clause under CISG, UCC and
UK Law." (2015).
Mai, Nan Kham. Exclusion and Limitation of Liability for Non-conformity of Goods: A
Comparative Study on CISG, UCC and UK Law. Diss. Niigata University, 2017.

15INTERNATIONAL TRADE LAW
Maier-Lohmann, Till. "Buyer’s self-repair of non-conforming goods versus seller’s right to
cure under Article 48 of the CISG." Uniform Law Review 24.1 (2019): 58-72.
Marsh, Peter. "Contract law." Contracting for Project Management. Routledge, 2017. 65-80.
Martin, Jennifer S. "Private Law Remedies, Human Rights, and Supply Contracts." Am. UL
Rev. 68 (2018): 1781.
Munoz, Edgardo, and David Obey Ament-Guemez. "Calculation of Damage on the Basis of
the Breaching Party's Profits under the CISG." Geo. Mason J. Int'l Com. L. 8 (2016): 201.
Muñoz, Edgardo. "Teaching comparaTive conTracT Law Through The ciSg." Indon. J. Int'l
& Comp. L. 4 (2017): 725.
Ramesh, Aditi, Petra Ghicu, and Cara Putman. "CISG v. UCC: Key distinctions and
applications." The Business & Management Review 7.5 (2016): 459.
Saunders, Kurt M., and Leonard Rymsza. "Contract Formation and Performance Under the
UCC and CISG: A Comparative Case Study." J. Legal Stud. Educ. 32 (2015): 1.
Schwenzer, Ingeborg, and Ilka Beimel. "Replacement and Repair of Non-Conforming Goods
under the CISG." Internationales Handelsrecht 17.5 (2017): 185.
Schwenzer, Ingeborg. "Ethical standards in CISG contracts." Uniform Law Review 22.1
(2017): 122-131.
Schwenzer, Ingeborg. "The CISG–A fair balance of the interests of the seller and the buyer."
(2016): 79-91.
Singh, Lachmi. The United Nation Convention on Contracts for the International Sales of
Goods 1980 (CISG) An examination of the buyer’s remedy of avoidance under the CISG:

16INTERNATIONAL TRADE LAW
How is the remedy interpreted, exercised and what are the consequences of avoidance?. Diss.
University of the West of England, 2015.
Stone, Richard, and James Devenney. The modern law of contract. Routledge, 2017.
Wu, Xiyuan. "The Mitigation Rule and Impacts of Overdue Payments in International
Business." (2018).
Zareshahi, Ali. "A Comparative Study of Damages and Price Reduction Remedy for Breach
of Sale Contract under CISG, English and Iranian Laws." J. Pol. & L. 9 (2016): 126.