This is a study of personal injury compensation in six European jurisdictions. Belgium, France, Germany, Netherlands, Sweden and the U.K. The study was sponsored by the International Association for the Study of Insurance Economics (“The Geneva Association” founded in 1973). The sections contributed by the national reporters contain much valuable information for lawyers and insurers with transnational practices. The final General Report, written by Werner Pfennigstorf, draws out the themes from these sections and provides stimulating reading for those interested in the broader problems faced by accident compensation systems. It provides an excellent conclusion to an important contribution to comparative studies.

The national reports take the form of a brief introduction to the law of the jurisdiction and, in particular, the way in which tort, insurance and social security compensation systems are coordinated. This is followed by a section detailing the application of the rules to 15 model cases ranging from road accidents through medical negligence to environmental contamination. The compensation figures suggested by the national reporters vary widely. In the case of the environmental contamination, for example, the U.K., reporter, Fred Collins of Eagle Star, suggests £36,500 for the personal injury liability. The French reporter suggests FF45,000 for the same loss but excludes a number of items as not proven. The German reporter suggests a liability figure of DM601,000—but that is to cover the decontamination costs to the government rather than the personal injury liability, which was estimated at a mere DM100. This is a rather extreme example of the disparities to be found in all model cases. Direct comparisons are somewhat hindered by the different assumptions adopted by the reports and, in this pre-E.M.U. Community, by the lack of a single currency; perhaps conversion of the national currency figures into ECUs would have assisted comparisons. But as Pfennigstorf explains in his introduction, the purpose of the model cases and suggested figures is not to enable comparisons to be made; it is to provide illustrations of the general