ABSTRACT
Our task is now to summarize and compare the results contained in the national reports. In order to give the reader a helpful overview, we have arranged the results in a series of charts, and at the end of the section we discuss a number of findings and make comparative comments based upon them. Chart I organizes the answers country by country, and we have continued to use the Liberal, Pragmatic and Conservative regimes as our ordering principle. Chart II compares two theories of relief, delictual and contractual, and shows the extent to which legal systems make recourse to contractual ideas as an alternative to tort. Here the countries are simply arranged by the degree to which they rely on these two grounds instead of the single ground of tort. Chart III breaks down the results for a number of widely-recognized paradigm cases (fitted to our taxonomy),1 and once again the results are organized in terms of the Liberal, Pragmatic and Conservative regimes.
