A comparative study of civil liability due to accidents with pedestrians in Iran, England and France

Number of pages: 158 File Format: word File Code: 29665
Year: 2012 University Degree: Master's degree Category: Management
  • Part of the Content
  • Contents & Resources
  • Summary of A comparative study of civil liability due to accidents with pedestrians in Iran, England and France

    Traffic Sciences and Arts

    Thesis of Master's Degree in Traffic Management

    Abstract:

    One of the most important traffic accidents is the accidents of moving vehicles with pedestrians, which have a very high frequency at the level of different societies. with pedestrians in Iran, England, and France. In this research, library and document methods were used to collect the required data and information. In the sense that the required information has been collected by studying the available and related written sources including books, articles, publications, booklets, theses and scientific research.

    The results of this research show that since 1985 in France, the rules of absolute liability in vehicle accidents with pedestrians have prevailed and significant support for the injured (pedestrians), especially people under 16 years and over seventy years and people with more than 80% while in England they mainly refer to the traditional rules of fault in this case (vehicle accidents with pedestrians) and in this regard the courts only set a high standard for taking care of pedestrians and in Iranian law, the legislator did not limit himself to the general rules of civil liability in vehicle accidents with pedestrians and due to the importance of the issue, he established special provisions in this regard and by approving Article 26 of the traffic violations law approved in 1989, he took a step towards compensating the injured

    Key words:

    civil liability (accidents) - pedestrian

    Chapter One

    Generalities

    * Introduction

    *Statement of the problem

    *Objectives Research

    *Importance and necessity of research

    *Research questions

    *Research background

    *Research limitations

     

     

     

     

     

     

     

    1- General:

    1-1- Introduction:

    The necessity of human social life is to have relationships and the necessity of society members to have relationships with each other is the occurrence of harmful events. For this reason, human social life has always been accompanied by harmful events, and as a result, the compensation of the victims and the civil responsibility of the perpetrators of harmful acts have been discussed. Therefore, considering that the occurrence of harmful events for humans is inevitable; Civil responsibility is a cognate of human social life, in this regard, human beings have always sought to establish rules based on which to impose responsibility and damage on the person who had the most role in the harmful incident. Therefore, the whole mission of civil liability is to identify such rules. Nowadays, in most countries, in parallel with technical and industrial developments, harmful accidents have also increased. Due to the inefficiency of the previous rules of civil responsibility, there were developments in this field, and according to the type of accidents, these rules were also changed, in such a way that due to the increase of harmful accidents caused by new technologies, the number of special responsibilities was increased. Accordingly, civil liability rights have evolved even more and compared to the past needs more.

    One of the most important traffic accidents is the accidents of moving vehicles with pedestrians, which have a very high frequency at the level of different societies, and due to the importance of this issue, legislators in different countries have tried to establish regulations in these cases. Shortcomings in the field of accidents with pedestrians, by using the legal laws of other countries, helped to amend the existing laws and develop new laws. Therefore, in this research, it has been tried to take a step towards the realization of the intended goals with a comparative study of civil liability caused by accidents with pedestrians in Iran, England and France.The content of this research consists of 5 chapters: the first chapter, stating the generalities of the research, including the statement of the problem, research objectives, importance and necessity of research, research questions and research background; The second chapter, theoretical and research foundations; In the third chapter, the conditions of responsibility and non-responsibility of the driver in accidents with pedestrians on special and general roads in Iranian law and British and French law are mentioned, and in the fourth chapter, the effects of pedestrians' fault in the civil liability of drivers are discussed and investigated, as well as the damages that can be claimed by pedestrians in the laws of Iran, England and France, and finally, in the fifth chapter, the results obtained from the research and suggestions are presented.

    1-2- Statement of the problem:

    One of the most important traffic accidents is the accidents of moving vehicles with pedestrians, which have a very high frequency in society, so that the amount of pedestrian accidents (casualties and injuries) in recent years has accounted for a significant part of traffic accidents. In Iran, more than 30% of accidents and 23% of traffic fatalities are pedestrians. (Safarzadeh, 2010, p. 233) Also, due to the fact that pedestrians are directly exposed to collisions with vehicles without any protection, therefore, we see many injuries and casualties in such accidents. Drivers who have played a role in these accidents and are influential, and as a result of correcting the behavior of the aforementioned and other persons who are involved in these accidents, such as manufacturers, vehicle repairers and traffic guards, in addition to this legal protection of pedestrians even in cases where they are completely at fault and the cause of the accident, the legislators in different countries have enacted regulations in these cases. Passages and specific legal protections for them can be useful.

    In this research, what are the terms and conditions of civil liability resulting from accidents with pedestrians in Iran, England and France?

    For this purpose, by referring to the library and using legal books, as well as searching the Internet and translating articles and Latin books collected in this field, a comparative study of the legal laws of Iran, England and France in relation to civil liability resulting from accidents with By comparing the legal situation of Iran with the mentioned countries, the shortcomings of the country's legal laws in the field of accidents with pedestrians can be revealed by using the legal laws of other countries and they can be fixed by amending the existing laws and drafting new laws. Also, by using these laws, it has significantly helped to improve the behavior of drivers and pedestrians, vehicle manufacturers and repairers, and road guards, and ultimately reduced such accidents in the country and increased the awareness of jurists. and accident experts in dealing with the mentioned accidents.    

    1-3- Objectives:

    1-3-1- The main objective:

    Study and explain the different legal aspects of accidents with pedestrians in the laws of Iran, England and France in order to identify the strengths and weaknesses of the laws of the mentioned countries in relation to the civil liability of drivers in accidents with pedestrians.

    1-3-2- Secondary objectives:

    1) A comparative study of accidents with pedestrians Pedestrians and conditions of driver's lack of responsibility on special roads. 2) Comparative study of accidents with pedestrians and conditions of driver's lack of responsibility on public roads. 3) Comparison of the legal situation of Iran with England and France regarding the conditions of legal protection of pedestrians in accidents.

  • Contents & References of A comparative study of civil liability due to accidents with pedestrians in Iran, England and France

    List:

    Chapter One

    Generalities

    1-1-Introduction..2

    1-2-Statement of the problem..4

    1-3-Objectives..5

    1-3-1-Main objective..5

    1-3-2-Sub-objectives..5

    1-4-Importance and necessity of research.6

    1-5-Main research question.7

    1-6-Research sub-questions.7

    1-7-Research background.7

    1-8-Research limitations.10

    1-9-Research method..11

    1-10-Collection method and tool Information. 11

     

     

     

     

    Chapter Two

    Theoretical foundations of research

    2-1- Concept and definition of responsibility. 13

    2-2- Division of responsibility. 13

    2-2-1-Ethical responsibility. 13

    2-2-2-Legal liability and its types.13

    2-2-2-1-Criminal liability.14

    2-2-2-2-Civil liability.15

    2-3-Comparison of civil liability and criminal liability.18

    2-4-History of civil liability.20

    2-5- Importance Pedestrian accidents. 24

    2-6-Basics of civil liability. 25

    2-6-1-Fault theory. 25

    2-6-2-Risk theory. 27

    2-6-3-Right guarantee theory. 28

    2-7-Resources of civil liability. 30

    2-7-1-Resources General. 31

    2-7-1-1-Waste. ....31

    2-7-1-1-1-the concept of waste. 31

    2-7-1-1-2-the conditions of waste. Tasbib. 35. 2-7-1-3-Community of cause and effect. 38

    2-7-1-3-1-Concept of community of cause and effect with separate effect. 38

    2-7-1-3-2-Concept of community of common cause and effect. 38

    2-7-1-3-2-1-Distribution of responsibility between cause and effect (different assumptions in community of cause) 39

    2-7-1-3-3-The concept of independent cause and effect association. 43

    2-7-1-4-Association of several stewards in general. 46

    2-7-2-Special sources of civil liability resulting from accidents with pedestrians. 48

    2-7-2-1-Article 333 of the Penal Code Islamic.50

    2-7-2-2-Article 4 of the Road and Railway Safety Law.50

    2-7-2-3-Article 8 of the Law on Handling Violations and Collecting Penalties approved in 1350 and the commentary on the said article.51

    2-7-2-4-Article 26 of the Law on Handling Traffic Violations approved in 1389.53

    Chapter 3

    Terms of responsibility and non-responsibility of drivers in accidents involving passengers in the laws of Iran, England and France

    3-1- Classification of legal systems. 55

    3-2-Civil liability of drivers in vehicle accidents with pedestrians in French law. 56

    3-2-1-Compensation for direct damage to a person, including drivers and others. drivers 58

    3-2-1-1-Compensation of damages for non-driver victims. 58

    3-2-1-1-1-Non-driver victims with special protection. 59

    3-2-1-1-2-Other non-driver victims. 60

    3-3-Civil liability of the driver in vehicle accidents with pedestrians in English law 67

    3-3-1-pseudo-crime and conditions for its realization. 68

    3-3-1-1-conditions for realization of pseudo-crime. 68

    3-3-2-how to apply the conditions for realization of pseudo-crime to traffic accidents. The relationship of causation. 3-3-2-3-Reasonability and the rules governing it as criteria for breach of duty. 73

    3-3-2-4-Proof of fault or carelessness. 74

    3-4-Civil liability of the driver in vehicle accidents with pedestrians in Iranian law. 76

    3-4-1-Article 333 of the Penal Code. Islamic. 76

    3-4-1-1- Examining conditions of non-responsibility of the driver according to Article 333 m. A. 77

    3-4-2-Article 4 of the Road and Railway Safety Law. 80

    3-4-2-1-Examination of the driver's non-responsibility conditions according to Article 4 of the Road and Railway Safety Law. 82

    3-4-3-Article 8 of the Law on Handling Violations and Collecting Penalties approved in 1350 and the note of the mentioned article. 90

    3-4-3-1- Examining the conditions of non-responsibility of the driver according to Article 8 of the law on handling violations. 92

    3-4-3-2- Examining the conditions of non-responsibility of the driver according to the note of Article 8 of the law on handling violations. 92

    3-4-4-Article 26 of the law on handling traffic violations approved in 1389. 94

    3-4-4-1-Reviewing the conditions of Article 26 Law on handling traffic violations approved. 1389. 95

    3-5- Claimable damages by pedestrians in the laws of Iran, England and France. 97

    3-5-1- Concept of damage. 97

    3-5-2- Division of damage from different directions. 98

    3-5-3- Claimable and coverable damages. 100

    3-5-3-1-Unitary systems and unlimited damage coverage (Unitary systems). 100

    3-5-3-2-Two-tier systems (Two-tier systems). ..109

    4-2-Historical Background of Damaged Fault in World Legal Systems. 111

    4-2-1-Historical Background of Damaged Fault in Foreign and Iranian Legal Systems. 111

    4-2-1-1-Roman Law.

    4-2-1-3-French law.114

    4-2-2-Iranian subject law.114

    4-3-Conditions of effecting the fault of the victim on the responsibility of the cause of the loss. The fault should not be the cause of the loss. 117

    4-4-Specific features of different assumptions of the common fault rule. 118

    4-4-1- The first assumption: the injured party is responsible for the actions of the cause of the loss. 118

    4-4-2- The second assumption: There is evidence of responsibility against the injured party. 119

    4-5-The various forms of the fault of the injured party and its effects. 120

    4-5-1-1- The first assumption: the fault of the cause of the loss should eliminate the fault of the victim. 120

    4-5-1-1-1- The fault of the cause of the loss should be more severe than that of the victim. 121

    4-5-1-1-2- The fault of the victim should be the result of the fault of the cause of the loss. 125

    4-5-1-1-3-Detailed and applied review in the legal systems of Iran, England and France. 125

    4-5-1-2- The second assumption: the fault of the injured party must eliminate the fault of the cause of the damage. 129

    4-5-2-The damage was attributed to the fault of both (a special example of joint fault). 130

    4-5-2-1-The criteria for sharing responsibility in foreign legal systems (England and France) and Iran's subject law...131

    4-6-Summary. References 148.

    .

    Source:

    Persian sources:

    1) Al-Hosseini al-Maraghi, Seyyed Mir Abdul Fattah. (1385), "Anawin Daman", translated by Mohammad Javad Shariat Bagheri, first edition, Mizan Publishing.

    2) Al-Sanhouri, Ahmad Abdul Razzaq. (1384), "Course of Laws of Obligations and Sources of Obligation", translated by Dammarzi and Danesh Kia, Qom University Publications, Volume II.

    3) Emami, Seyyed Hassan. (1364), "Civil Rights", third edition, Islamia bookstore, first volume.

    4) Bariklou, Alireza. (1385), "Civil Responsibility", Mizan Publication.

    5) Bariklo, Alireza. (1389), "Civil Responsibility, Mizan Legal Foundation, third edition.

    6) Bulgari, Mohammad. (1380), "Collection of traffic rules and regulations, transportation and traffic matters", Majd Publications, second edition.

    7) Pasha Saleh, Ali. (1348), " Discussions on the History of Law", Tehera University N. 8) Teofil, Mik. (1373), "The Code of Hammurabi", translated by Kamiyar Abdi, Mashal Azadi Publishing, Volume 1. 9) Jaafari Langroudi, Mohammad Jafar. (1376), "Legal Terminology", 8th edition, Ganj Danesh Publications. 10) Javan, Musa. (1326), "Fundamentals of Law", Color Printing Company, first volume.

    11) Khodabakhshi, Abdulla. (2009), "Fundamental distinction between civil rights and criminal law, Tehran, Shahr Danesh Institute of Legal Studies and Research, first edition.

    12) Khodabakhshi, Abdullah. (2010), "Workers' compensation in the civil liability system", Tehran, publishing company, first edition.

    13) Khodabakhshi, Abdullah. (2013), "Civil liability arising from traffic accidents and its developments in Iranian law", Judiciary Law Journal, year 75, number 74.

    14) Rahepik, Hassan. (1387), "Civil Liability Laws and Obligations", Khorsandi Publications.

    15) Jordan, Patrice. (1382), "Principles of Civil Liability", translated by Majid Adib, Mizan Publishing House.

    16) Shahidi, Mahdi. (1381), "Works on Contracts and Commitments", Second Edition, Majd Publications, Volume III.

    17) Safarzadeh, Mahmoud, Hasanpour, Shahab, Abdi, Ali.(2018), "Study of Pedestrian Accidents in Iran and Providing Solutions to Improve Their Safety", Road Quarterly, No. 69, Winter 2019.

    18) Safai, Seyyed Hossein, Rahimi, Habib Elah. (2019), "Civil Liability (Non-Contract Obligations)", Samit Publications, Tehran, Print 1.

    19) Tahmasabi, Javad. (2008), "Discourse on the Scope of Liability in the Compulsory Insurance Reform Law", Judiciary Legal Journal, Year 73, Number 68.

    20) Abbaslu, Bakhtiar. (2018), "Civil Liability Due to Driving Accidents", Second Edition, Tehran, Mizan Publishing.

    21) Abbaslu, Bakhtiar. (1390) "Civil Liability (with a comparative perspective)", first edition, Tehran, Mizan Publishing.

    22) Abbaslu, Bakhtiar, Kashfi, Saeed. (1389), "Developments in the law amending the law on compulsory civil liability insurance of owners of motor vehicles against third parties", Traffic Management Quarterly, No. 19.

    23) Farhani, Ahmad. (1384), "A new look at liability" (Civil) resulting from the accident of a vehicle and a pedestrian on the freeway (legal analysis of Article 4 of the Road and Railway Safety Law)", Police Knowledge Quarterly, Year 7, Number 3.

    24) Farhani, Ahmed, Shirzad, Jalal, Kashfi, Saeed. (2018), "Police and Innovations of the New Compulsory Insurance Law and Its Basics", Police Knowledge Quarterly, Year 13, Number 1.

    25) Qasim Zadeh, Morteza. (1386), "Requirements and civil liability without contract, Tehran, Mizan Publishing.

    26) Qasemzadeh, Seyed Morteza. (1383), "Fundamentals of civil responsibility" Mizan Publishing, second edition, Tehran.

    27) Qasemzadeh, Morteza. (1372), "Theory of fault", doctoral thesis, Tehran, Tarbiat Modares University.

    28 ) Katouzian, Nasser.(1374), "Civil rights, non-contractual obligations (compulsory guarantee)", first edition, Tehran, Tehran University Press, vol.1-2.

    29) Katouzian, Nasser. (1378), "non-contractual obligations, compulsory guarantee, civil liability", second edition, Tehran, Tehran University Press, volume 1.

    30) Katouzian, Nasser.(1371 and 1372), "The nature and scope of debt - damage caused by crime", Lawyers' Association magazine, No. 6-7

    31) Katouzian, Nasser, Laia Junidi and Majid Ghamami. (1381) "Civil liability due to traffic accidents", Tehran University Press.

    32) Kihani, Mansour. (1342), "Rome Laws - Obligations", Tehran, Taban , first volume.

    33) Lorasa, Michel. (1375), "Civil Responsibility", translated by Dr. Mohammad Ashtri, Tehran, publishing house.

    34) Damad, Sayyed Mustafa. (1382), "Jurisprudence - Civil Section - Ownership and Responsibility", second edition, 10th edition, Islamic Sciences Publishing Center.

    35) Mohammadi, Abolhasan. (1386), "Fundamentals of Inference of Islamic Laws", 29th edition, University of Tehran Press.

    36) Mousavi Bojunordi, Seyyed Mohammad. (1368), "Jurisprudence Rules", Islamic Revolution Publications and Education Organization.

    37) Nojomian, Hossein. (1348), "The field of comparative law in the Islamic, French, English and Russian legal systems", Mashhad, Toosi Printing House. .

    38) Walidi, Mohammad Saleh.(1373), "General Criminal Law", published, first volume.

    39) Wiene, Genevieve, Patrice Jourdan. (1384), "Accompaniment of the verb attributed to the recipient and the injured verb", translated by Majid Adib, Journal of Legal Research, No. 42.

    40) Wiene, Genevieve Patrice Jourdan. (1384) "The fault of the victim in traffic accidents", translated by Majid Adib, Journal of Legal Research, No. 42. 41) Yazdanian, Alireza. (1379), "Civil rights of the territory of Masdeo Lit Madani, Adebistan Publishing House.

    Arabic sources:

    1) Al-Hakim, Abdul Majid. (1963), "Al-Mujaz fi Sharh Al-Madani Al-Abidim (Sources of Obligation)", second edition, Baghdad, Al-Tabb and Al-Nashar.

    2) Al-Sanhouri, Abdul Razzaq. (1988), "Al-Wasit fi Sharh Al-Madani Al-Abadim", first part, Al-Abadim. Beirut, Dar Ihya Al-Trath Al-Arabi.

    3) Al-Awji, "Al-Madaniyyah", Beirut, Al-Halbi's al-Hawqiyya manifesto. 4) Hali (Allameh Hali), (1991 AD), "Hamal al-Din Abi Mansour al-Hassan Qa'aba al-Ahkam", contained in: Al-Alinabi' Al-Faqhiyyah Series, Beirut, Dar al-Trath al-Arabi and Dar al-Islamiyya Publications, vol. 25.

    5) Shahid Thani, Zain al-Din Ali al-Omili. Al-Damshaqiyyah", offset printing, two-volume series, Mohashi, Tehran, Islamia Book Store Publications.

    6) Oudah, Abdul Qadir. (1408), "Al-Islamic Criminal Law in comparison with the statutory law", Darlaktab Al-Alamiya.

    7) Mohammad Allahabi, Saleh Ahmad. (2004), "Dijaga and al-Musab fi al-Msamouliteh al-Taqsiriyyah", Amman, Dar al-Taqafeh, for publication and distribution.

    8) Marqs, Suleiman. (1992), "Al-Wafi fi Sharh al-Qunun al-Madani fi al-Obligadat fi al-Dhar and al-Responsibility al-Madinah", Volume 1, Egypt: Al-Cairo Society.

    9) Mustafa al-Khomeini, Ruhollah, "Tahrir al-Wasila", volume two, Quds Mohammadi Publications, Bita.

    10) Mansour, Muhammad Hossein. (1995), "Sharh al-Aqud al-Masmah (in Egypt and Lebanon), Al-Jaz Al-Thani al-Tamin, Lebanon, Dar al-Nahdah al-Arabiya."

    Latin sources:

    1) BAKER (C. D.) (1991): "Tort", 5 th edition, sweet & Maxwell, London. 2) Clerk & Lindsell, (1995), "Torts", 7 th edition, sweet & Maxwell, London, nos 7-01 & 7-04, pp. 217 & 219

    3) FLEMING (John G.), (1971): "Law of torts", 4 th edition, Law book co. limited. Australlia.

    4) MARTY (Gabriel) et RAYNAUD (Pierre) (1988): “Droit civil”, Les obligations, 2e edition, T. 1, Les sources, sirey.

    5) MAZEAUD (Henri et Léon–Jean).(1970), “Traité théorique de la responsabilité civile”, deliectuelle et conteactuelle, preface. Par Henri capitant, T. II, 6e edition, Montcherstien.

    6) PADFIELD (C. F.), BARKER (D.L.) (1989),” Law Made simple”, 7th edition, Heinemann, London.

    7) ROGERS (W. V. H.) (1994): “Winfield and Jolowicz on tort”, 4th edition, sweet & Maxwell.

    8) Vivienne Harpwood, "Modern tort law" (2003), London, Cavendish publishing Limited, p 1.

A comparative study of civil liability due to accidents with pedestrians in Iran, England and France