ABSTRACT

Article 7 CISG stipulates that the Vienna Convention must be interpreted having regard to its international character and the need to promote uniformity in its application. It is well established in literature and case law that the ‘international character’ of the CISG demands that its terms and concepts be interpreted autonomously; that is ‘in the context of the Convention itself and not by referring to the meaning, which might traditionally be attached to them within a particular domestic law.’1 Courts are also expected to abandon the literal or grammatical approach in favor of a purposive one because, in interpreting the CISG, regard must be had to the ‘underlying purposes and policies of individual provisions as well as of the Convention as a whole’.2