A Comparative Study of Civil Liability in Imami Jurisprudence, Iranian and British Law

This research has been done with the aim of examining the general rules of civil liability and its analysis and comparative study in Iranian and British law and Imami jurisprudence by analytical descriptive method. The results show that in English law, the general rules of civil liability are referred to as: liability for negligence, intentional and fault-free liability, of which negligence and liability are the most important. Civil liability in Iranian law includes: liability based on fault and no fault, the rule of causation and loss is the main element of liability based on fault and no fault, respectively. However, in Imami jurisprudence, liability based on fault and without fault is considered as a unit and contrary to Iranian law, the rule of loss and causation are not independent of each other. However, causation is not the main element of liability and mere realization of the loss does not create a guarantee without a loss factor. Finally, despite the apparent differences, the general rules of civil liability in these three systems; They are adaptable and have a common goal: "administration of justice and full compensation for wrongdoing."