Comparison of economic loss compensation in Iranian law and the legal systems of world countries

Among foreign countries, there are three different attitudes regarding the ability to compensate economic losses. Some countries, such as the United Kingdom and the United States, have considered the economic loss unclimbable; except in exceptional cases such as intentional damage to others. The same procedure has been proposed in some other countries such as Germany. But to count the exceptional cases, different solutions have been proposed. On the other hand, countries like France, by applying a free-thinking perspective, have placed the principle on the ability to compensate for such damages. In Iranian law, the principle is on the ability to compensate for economic loss, provided that the conditions for claiming the loss, such as the foreseeability of the loss or its directness, are met. Considering the importance of the topic of this study, with the aim of comparing the compensation of economic loss it has been carried out in the laws of Iran and the legal systems of the countries of the world.

کلیدواژه ها:

claimable loss conditions ، economic loss ، compensability ، civil liability