International Personal Injury Compensation Sourcebook and Yearbook: 1996.

• Author: Hodges, Christopher J.S.

Reviewed by IADC member Christopher J.S. Hodges, McKenna & Co., Solicitors, London.

This book sets out to compare answers to the question "What compensation can be obtained for personal injuries?" in 20 countries: Australia, Austria, Belgium, Canada, Denmark, England and Wales, Finland, France, Germany, Greece, Ireland, Italy, Mexico, the Netherlands, New Zealand Norway, Scotland, Spain, Switzerland and the United States.

A chapter is contributed on each country by a local lawyer, and each follows a similar format. The chapters are well written with helpful headings. The book gives a reasonably clear idea of "What heads of loss are recoverable?" but inevitably the answers are generalized, as they must be in a book of this type. And the answers can be long or short; one can have either much detail and many authorities or, as here, a reasonable summary for as many countries as possible.

The book is one of a sequence of comparative studies emanating from the Center for International Legal Studies in Salzburg, and it inevitably focuses on European jurisdictions. As such, it may be a precursor to a European Commission initiative to harmonize EU laws in this area, but don't hold your breath! There is a brief foreword contributed by a member of the center, but this is disappointing. It wastes the opportunity of attempting to summarize themes of convergence and divergence in the national approaches and merely reveals a limited and biased polemic for justice for victims. Of greater use is the final chapter by the center on the Brussels and Lugano jurisdiction and enforcement conventions.

The sourcebook states the general, overview position. It covers headings such as: general bases of compensation; special bases of compensation; who may recover; how to recover (with a description and diagram of the court structure); who may be liable; types of damages; insurance; and costs and funding (including legal aid). But since the areas of law covered are so wide, it is intended that there will be an annual yearbook with updating information. This may well turn out to be a very useful reference since, on the evidence of the 1996 Yearbook, recent developments are reviewed in some detail.

For example, case reports and some safety statistics make for interesting reading. A comparison of deaths per 100,000 inhabitants in Austria, the United States and the two former parts of Germany shows consistently higher mortality, in general, on account of cardiac or...