CONTRACT LAW IN THAILAND: A PROPOSAL FOR REFORM OF THAI SALES LAW AS COMPARED WITH JAPANESE CONTRACT LAW AND CISG

Abstract

Currently in Thailand, there are no specific laws governing domestic commercial sales and international sales which apparently cause legal obstacles. The sales provisions provided in Thai Civil and Commercial Code (“TCC”) are the only set of Thai law applying to all types of sales which are distinct in nature. As Thailand and Japan share similar legal histories and backgrounds in following the Civil Law legal system originated in the Continental Europe, and Japanese Civil Code (“JCC”) was also the forerunner of TCC when the time of its first drafting in 1905, any revision made in JCC is of significance to TCC.