CAUSA AND CONSIDERATION – A COMPARATIVE OVERVIEW

The article examines the Roman origin and historical development of "causa" as an essential requirement of the contracts, as well as its adoption in the majority of the national legislations belonging to the French legal family. Moreover, the article analyzes what has become to be known as the functional equivalent of causa in the English law – the doctrine of consideration and examines the correlation between them. In the end, the latest tendencies in codifying the European civil law with respect to causa and consideration are being critically discussed.