ABSTRACT
Good faith also occurs in the Unidroit Principles of International Commercial Contracts. Good faith and fair dealing, it explains, may be considered to be one of the fundamental ideas underlying the Principles. A similar provision is contained in the Lando Principles of European Contract Law. Good faith is also mentioned in the Gandolfi Code Europen des Contrats, which contains an article dealing with obligation of good faith. The Draft Frame of Reference asserts that a person who is engaged in negotiations has a duty to negotiate in accordance with good faith and fair dealing. Eminent academics offer no fewer than three different meanings of the good faith principle, giving grounds to doubts about the introduction of such a principle in European law. The old negative attitude toward good faith in Common Law countries also expressed in terms of superfluity or neutrality seems to be changing, if not being rejected outright.
