Comparative maritime law - H. Cherkaoui - A.m.d.m.a. - broché - Etude

This is the first book in the world engaged in the unexplored study of comparative maritime law. This comparison was made with respect to the Moroccan Maritime Code of 1919 which was inspired by several foreign maritime laws and by international conventions implemented later. This Code was, incidentally, the first in the maritime world to consider the protection of shippers by referring to the U.S. Harter Act of 1893, which was introduced in its provisions. Analyses undertaken in this book delve into many foreign maritime laws, in particular English, French and American laws. Those chapters devoted to the comparison of Moroccan maritime law with that of 19 other countries yields differences more of detail than of principle. Often, the distinctions that may be made are mitigated by the use of the same international conventions. Morocco, like most of the other 19 countries analyzed in this book, is very supportive of the international unification of maritime law. While this comparative s