French - german view on the immaterial harm: two poles od tortious system and inspiration for Czech legislator
2011
Abstract
The article deals with the immaterial harm as a personal dammage. It compares two different points of view.
On the one hand, the French model with the open general delictual norm and the German system with specially listed rights and values protected by the law on the other hand. Both in a way to inspire our legislator de lege ferenda.