engleski

Hotel-keepers' liability for guests' property under the European Convention (Paris, 1962) and comparative law

The European Convention on the Liability of Hotel- Keepers Concerning the Property of their Guests (1962) is the only unified source regarding hotel- keepers' liability for the property of guests. The purpose of this paper is to demonstrate the conventional solutions and analyse their impact on comparative European and Anglo-American laws, on international law and on the law of the European Union (EU). The methodology of the paper is conceptualised through three degrees of the hotel- keepers liability for damage, loss or destruction of guests' property: unlimited, limited and excluded. The results of the paper are answers to theoretical problems (nonproprietary damage, the differences between the two great legal circles (Euro-Continental and Anglo-American), limit of the liability, the concept of force majeure) and practical problems (proving and insuring the damage, non-harmonised law in the EU, the application of the Convention) that the Convention imposes. The Convention is an excellent foundation for the creation of an international convention that would reconcile the differences between Euro- Continental and Anglo-American law regarding the hotel-keeper's liability for guest property.

personal property ; hotel guests ; Council of Europe ; hotelkeepers ; European Conventions ; Anglo-American law ; international law ; EU ; UK ; USA ; unlimited liability ; limited liability ; excluded liability ; non-proprietary damage ; legal differences ; comparative law ; private law.

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