General issues of liability for harm caused for life and health in Germany and Kazakhstan: comparative analyses

Аннотация

This article deals with the comparative analyses of legislation of Germany and Kazakhstan on liability for harm caused for life and health. The system of tort legislation of Kazakhstan and Germany is shown. The differences between the German Civil Code and the Civil code of the Republic of Kazakhstan are demonstrated. Also common features of these normative acts are defined. Moreover, advantages and disadvantages of both sides are analyzed.
Key words: tort obligation, life, health, Germany, Kazakhstan.