ABSTRACT
All legal systems have incorporated some legal way to settle this discomfort, albeit in different ways. It needs to be noted that in this context both the terms ‘non-performance’ and ‘breach of contract’ are used. In brief, civil codes inspired by the civil law legal family usually adopt a legal remedy to enforce fulfilment of the obligations of a contract as a primary legal remedy. In common law systems, there is a stronger emphasis on damage compensation rather than demanding the specific performance that was agreed upon. Islamic law also focuses on damage compensation, but in a more restricted way. An example of a civil law solution is provided by the Japanese Civil Code, inspired by the German Civil Code. Jennifer Lopez was invited to perform on a special celebration day that embarks the 10th anniversary of the hotel. Most civil law systems however make an exception when the impossibility is a result of a so-called ‘force majeure’.
