Harmonizing the Standard of “Fundamental Breach” under Article 25 CISG - A Comparative Analysis of Selected EU Case Law and the Role of UPICC
This thesis examines the interpretation of fundamental breach under Article 25 of the United Nations Convention on Contracts for the International Sale of Goods, focusing on judicial divergences between Germany and France in the context of supply-chain disruptions occurring between 2019 and 2025. Article 25 establishes substantial deprivation of contractual expectations as the gateway to avoidance
