ABSTRACT
All construction works are created by contract, some verbal, some written and some implied. The basis for these contracts is grounded in the law of the country in which the contract is executed (or the country agreed upon by the parties) and which ultimately governs its execution. For example, the FIDIC1 contracts state specifi cally that: “The Contract shall be governed by the law of the country (or other jurisdiction) stated in the Appendix to Tender”. The major legal systems worldwide that govern contracts are the common law, civil law and additionally that of Sharia law.
