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“South African, English and American law, generally refer to “reasonableness” in considering a number of elements of delictual or tort liability.”Reasonableness” is considered implicitly, however, where other terms or phrases reflecting reasonableness values or standards are used. …[W]hile jurisdictions following common law such as the United Kingdom and the United States of America easily refer to the concept “reasonableness”, other jurisdictions (like France) rarely do, but that does not mean that lawyers of the different jurisdictions think differently. It just means that they speak differently.”
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