Classification of Contractual Agreements in Comparative and Islamic Jurisdictions: Does it Make Any Sense?
Abstract Comparative legal systems differ in the organization of the manifestation of parties’ expressions when making legal transactions where an external action does not reflect the real intention of this party. Most jurisdictions, including Islamic law, follow the objective theory of agreements while the Conterminal legal system adopts the subjective approach. Despite the fact that many scholars spent much efforts to clarify this classification, the importance of this classification may be modest; these legal systems organize some basic doctrines, with regard to the formation of a contract (namely: the revocability of offer, the need for communication of acceptance and the rules of interoperation), in a manner that may contradict with its general theory of making agreement. In other words, the organization of these doctrines has very little significant differences in result between these legal systems. Islamic law has the same result as well. This article aims at explaining these doctrines and differences.
Rationalizing anticipatory breach in Emirati law: A comparative legal study with English law
The Dubai Court of Cassation ruled a new trend in 2013 by creating the principle of anticipatory breach in a real estate appeal in Emirati law despite the fact that no similar doctrine is known to exist under this law. This doctrine is found in common law legal systems; it authorizes the innocent party to terminate the contract and sue for damages if there are serious grounds to believe that the other party will not perform his future obligations, even though the time of this performance is not yet due. UAE law, and likewise French law, recognizes the principle of an “actual” breach of contract; it must be a “present” to invoke the remedies of the agreement. This paper is meant to detect which bases the Dubai Court of Cassation relied on in the assessment of its decision in comparison with the nature of this doctrine (English law). It finally recommends the insertion of this doctrine in the general principles of contract law provided in the law of civil transactions with specific conditions and procedures.    
Within and Inter-Institutional Differences Between Death Certifiers on Autopsy Conclusions
This study seeks to establish whether medico-legal practitioners differ in their autopsy conclusions within and across medico-legal institutions. Data include 459 violent deaths (homicides, suicides, and accidents) autopsy reports written by more than 20 death certifiers from four medico-legal institutions in two countries (France and the United States). Multinomial models show that compared with accidental deaths, weapon use and decedents’ characteristics both influence a homicide verdict, but not a suicide one. In addition, French practitioners are more likely than Americans to reach a conclusion of homicide or suicide compared with accident, and homicides are more likely to be certified by male practitioners.