ABSTRACT
The idea of a European legal science must, therefore, not be exaggerated (cf Chapter 14). All the same, these comparative and theoretical points, particularly the problem of differing mentalities between the civil and the common law, need (given the EU) to be illustrated at a more practical level. This can be done by reference to an English tort case and a French product liability decision. The English case reflects not only a methodology and procedure shaped by history, but a mentality which does not function at the level of abstract rules. In contrast the French decision illustrates the interrelationship, at the general level, of the different categories of obligations (contract and delict) and the different kinds of liability which act as the basis for a compensation claim (fault and liability for things).
