This Note argues that it is essential to the success of the Sale of Goods Convention that the current controversy regarding exclusions be resolved uniformly by all ratifying nations. Part I discusses the negotiations that led to the Sale of Goods Convention’s exclusion provision. Part II identifies the Sale of Goods Convention’s primary goal of uniformity and the arguments promoting implied exclusions. Part III examines the arguments favoring express exclusions. This Note concludes that a uniform resolution allowing only express exclusions would be most consistent with the overriding principles of the Sale of Goods Convention.
Maureen T. Murphy,
United Nations Convention on Contracts for the International Sale of Goods: Creating Uniformity in International Sales Law,
12 Fordham Int'l L.J. 727
Available at: http://ir.lawnet.fordham.edu/ilj/vol12/iss4/4