Thesis:

A comparative study of the general rules of civil liability in Iranian law and English law with a view to jurisprudence

In English law, the general rules of civil liability are presented under the title: liability due to carelessness, intentionality and liability without fault, where carelessness and liability resulting from it are considered the most important. Civil liability in Iranian law includes: fault-based and no-fault liability, where the rule of attribution and loss is the main element of fault-based and no-fault liability, respectively. However, in Imamiyyah jurisprudence, responsibility based on fault and no fault is considered as a unit, and contrary to Iranian law, the rule of loss and attribution are not independent of each other. However, attribution is not the main pillar of responsibility and the mere realization of loss without the cause of loss does not create a guarantee. Finally, despite the apparent differences, the general rules of civil liability in these three systems; They have the ability to adapt and have a common goal: "executing justice and fully compensating the unjust loss". Although the structure and general image of the rules of civil liability in Western law, including England and the common principles of Iran and Imami jurisprudence, are different from each other in some cases. are considered independent for civil liability claims. This research aims to examine the general rules of civil liability and analyze and analyze and compare it in the laws of Iran and England and Imami jurisprudence with analytical and descriptive methods. Keywords: general rules of civil liability, liability due to fault, liability without fault, negligence

Keywords: general rules of civil liability, liability due to fault, liability without fault, negligence