Legal Effect of Electronic Contracts: A Comparative Study

FarisaTasneem

L.L.M (Monash University), PhD Candidate, RMIT University (Royal Melbourne Institute of Technology), Research Assistant, Monash University, Melbourne, Australia.

Corresponding Author: farisaif04@yahoo.com

Accepted 31 October 2013

Abstract

The aim of this chapter is to analyse the legislative approaches of other countries. The chapter seeks to explore how countries other than Australia have regulated electronic contracts. The chapter intends to demonstrate how the deficiencies examined are addressed by other countries, which have adopted different approaches. The chapter will specifically examine the legislative initiatives in regulating electronic contracts and electronic signatures in jurisdictions such as the US, the UK, Europe, Germany and Singapore. The chapter also discusses the recent development in the cases related to the enforceability of electronic contracts and electronic signatures. To avoid repetition, only those provisions that differ from the Electronic Transaction Legislation of Australia are discussed.

Keywords : Legal system, Electronic Contracts, Comparative Study.