مطالعه تطبيقي تعهد به دادن اطلاعات با تاكيد بر نظام هاي كامن لا

COMPARATIVE STUDY OF OBLIGATION FOR PROVIDING INFORMATION ON PRODUCTS WITH EMPHESIS ON COMMON LAW SYSTEMSʹ

Compelexity of the modern products in general and industrial products specially, causes the legislatores to impose an obligation on manufacturers and sellers to provide consumers with proper information and avoid giving wrong infromation about the products. In diferent legal systems , the basis of this obligation has been treated either contractual or noncontractual. In the former case , it has been justified as a part of obligation of deliverance or as expressed or implied warranty ; and in the latter case it has been interpereted in the framwork of laibitlity arising out or negligence or strict liability. The author attempts to gather the existant solutions and analyze them with reference to Common Law systems.