“When interpreting multilingual conventions, the question arises as to which language of the text is authentic, since the starting point for any legal interpretation is logically the wording of the law itself. This wording represents the immediate and “frozen” will of the legislature and must be followed by all courts because of their supremacy under the separation of powers. While multilingual conventions support their own international acceptance and represent valuable benefits for parties from different countries entering into a contract, there is also a side effect of a variety of interpretation options. There is a strict presumption in favour of the text, which an “international legislator” has declared authentic as representative of the actual will of the legislator with regard to the grammatical meaning of the text of the text. All texts that are not binding are excluded from an autonomous interpretation. The only texts that have become binding on the Court of Justice through the ratification of the Convention are those that have been declared authentic by the “international legislator”. An “official” translation of a multilingual convention into an inauthentic language contains only a prima facie presumption of its accuracy: it still requires examination and comparison with the authentic text(s). “Such abundance can cause two contradictory situations. On the one hand, it may be useful to look at the different formulations to resolve ambiguities. In this regard, each text contributes to the construction of the others and clarifies the intention of States parties. [1] However, the reverse can also be the case, and the advantages of many genuine versions become disadvantages. [2] It is extremely difficult to find equivalent expressions in six languages, and literal translations can be misleading.

[3] Moreover, since any community based on the rule of law tends to interpret a text with different cultural, linguistic and social reflexes, divergent constructions constitute a constant threat to the uniform application of the Convention at the international level. [4] The United Nations Convention on the International Sale of Goods (Vienna 1980): Some Significant Changes for the Practitioner, March 1994, p. 15 [Essay archived at the Institute of International Trade Law, Pace University Faculty of Law]. It can therefore be assumed that the English and French texts of the United Nations Convention on Contracts for the International Sale of Goods best reflect the intentions of the representatives at the 1980 Diplomatic Conference in Vienna with regard to the exact text of the final text of the Convention. The authentic English and French texts of the United Nations Convention on Contracts for the International Sale of Goods form the basis for the autonomous interpretation and definition of the concept of `products/marks` in Article 1(1). Keeping Uniformity in International Uniform Law Through Autonomous Interpretation: Software Contracts and the CISG, 8 Pace International Law Review (1996) 316-318 [Citations omitted] 3. Claude Samson, Methodology for the Uniform Application of International Conventions, Twelfth Congress of the International Academy of Comparative Law (Sydney/Melbourne: August 1986) 10 n.38. The aim is to present each official text and the texts of the United Nations Convention on Contracts for the International Sale of Goods in each of the languages into which it has been translated. There are also many unofficial translations of the CISG. 2.

Lord McNair, The Law of Treaties (Oxford: Clarendon Press 1986), p. 433. 1. In the judgment of 30. In August 1924, on the Mavrommatis-Palestine concessions, the International Court of Justice declared: “If two versions exist with equal authority, [a tribunal] is obliged to adopt the [version] corresponding to the common intention of the parties” (A Digest of the decisions of the International Court, Vol. 1, ed. K. Marek (The Hague: Martinus Nijhoff 1974) 104). Most users need to log in with their email address. If you originally registered with a username, please use it to log in. Nisreen Mahasneh, The Ratification of the United Nations Convention on Contracts for the International Sale of Goods by Jordan: the Legal Perspective and Impact, Uniform Law Review, Volume 16, Issue 4, December 2011, Pages 843–865, doi.org/10.1093/ulr/16.4.843 For a new website with additional features, go to The Uniform Law in Ten Languages, a support tool for variable and dynamic search of English texts, German, French, Spanish, Italian, Dutch, Swedish, Russian, Chinese and Japanese.

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