ABSTRACT
The conventional view about road traffic accidents is that liability to compensate victims of them should be dependent on fault, ie (in the normal case) negligence. However, in some countries the view is now taken that a victim of a road accident ought to be able to claim even if the person causing the accident was not at fault, because that person (being insured: there is a requirement of compulsory insurance against certain risks in all three countries) will be in a much better position to bear the loss than the victim. Both France and Germany take this view, but liability in France is significantly stricter than in Germany. England has maintained a fault-based system of liability.
