Alternative transaction in the laws of Afghanistan, Iran, and the International Sales Convention


Ibrahim Rezaei


Abstract

Social life is accompanied with various obligations, obligations that have forced the social necessities of the legislator to impose them on individuals or parties with freedom of will have undertaken it. The adaptation and implementation of legal and contractual obligations requires a performance guarantee. One of the obligations created by international commercial law for the parties of the contract is the alternative transaction in the assumption that one of the parties violates its contractual obligations. In the case of breach of contract from one side, the other party is committed to the mitigation of damage and one of the best ways for the mitigation of damage is to make an alternative transaction. In the absence of an alternative transaction and failure to the mitigation of damage, the victim will be deprived from the claim for additional damages that could prevent its entry and development. Convention on Contracts for the International Sale of Goods, the Principles of European Contracts and the Principles of International Commercial Contracts has explicitly determined this obligation on the responsibility of victim. This rule has not been explicitly raised in Islamic jurisprudence, including the Imamiyeh jurisprudence, but lawyers have tried to prove alternative transaction through rules such as the rule of prohibition of detriment, the rule of action, the principle of good faith, and... mitigation of damage. In Afghan law, the lawmaker in the law of trade contracts and the sale of property explicitly obliged the promisee to the alternative transaction, and it can be deduced from the provisions of civil law, but the Iranian legislator has explicitly failed to assign this duty to promisee. However, lawyers have invoked some articles of the law of commerce, civil law, Islamic punishment law, civil liability and good faith principle to prove the principle of coping with damages and thus to prove an alternative transaction. But the fact is that the proof of an alternative transaction in Iranian law is difficult according to the necessity and priority of the demand for the implementation of the object of obligation..



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