| There have been individualized conception models defining contrt in different historical periods and legal cultures, which has led to different contract law regimes in different legal systems. The classical Roman law established an obligatio一contractus system with formalism and nmerus clauses as the key features of contract;the medieval glossators accepted this model and redefined the contract with the doctrine of cause; the French law family continued this tradition and made the dsctrine of cause the key to understand the definition of contract and related rules; in Germany, after absorbing some elements of the theory of natural law and rationalism, the Romanists in the historical school reorganized the elemenu of contract with the theory of Rechtsgesch? ft, which abruptly changed the definition of contract for the second time in the history. The change of legal systems again led to new contract interpretation models in the 20th century. |
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