A COMPARATIVE ANALYSIS OF TRAFFIC ACCIDENT SYSTEMS

The World Tort Law Society ("WTLS") has set itself the task of investigating liability for traffic accidents from a global perspective. Such a comparative analysis is especially difficult given the fact that liability to compensate loss itself is already very variably structured across the individual jurisdictions. In some quarters, it has even in part been replaced or modified by no-fault compensation systems. Moreover, in order to achieve a realistic picture of how these losses are borne, it is also necessary to incorporate the various other instruments of loss distribution into the analysis-in particular the existence of compulsory insurance schemes or social insurance. This Article offers a first presentation of the results of this research.