Civil liability of principal against apparent authority of Agent and undisclosed principal - comparative study of Iran England law and International Documents

Expansion of international commercial and economic relations has led to the majority of commercial transactions being carried out by commercial agents.In the majority of transactions which are held out by commercial agents plenty of legal relations between principal, agent and third party are created. It may be ended to civil liability between principal, agent and the third party.The question of civil liability in contracts held by agents gets complicated when contracts that are held according to apparent authority of agents and in the case that agents have concluded the contracts apparently in his name, but actually on account of the principal.In this research the basis of principal's liability in such contracts have been compared in law of Iran, England and International documents. in sum, both the legal system of Iran and England have accepted civil liability of principal in such cases but with different approaches. Also under the convention on Agency in the International Sales of Goods 1983 this liability has been accepted.