ABSTRACT
Article 28 is one of the examples in the CISG that demonstrates the compromise that was necessary to reconcile common law and civil law traditions in the uniform international legal regime.212 It reads as follows:
If, in accordance with the provisions of this Convention, one party is entitled to require performance of any obligations by the other party, a court is not bound to enter a judgment for specific performance unless the court would do so under its own law in respect of similar contracts of sale not governed by this Convention.
