A. INTRODUCTION

Given the statement in the Introduction to PECL to the effect that one of the benefits offered by them “is to provide a bridge between the civil law and the common law” it is of some interest, particularly for those from so-called “mixed systems” like Scotland and South Africa, to try to detect major influences on parts of PECL. Are the PECL rules predominantly Civil Law, predominantly Common Law, or “mixed”? I will therefore consider the PECL rules on interpretation from this point of view before turning to what are for me more interesting questions – namely whether the PECL rules on interpretation are acceptable rules, and how they compare with the rules in Scottish and South African law.