In 2016, a new amendment regarding several general legal principles that govern and regulate financial transactions was introduced to the French Civil Code. The amendment was aimed at achieving a fair financial balance between all parties involved in various financial transactions, hence guaranteeing justice and equality between them. In this sense, this new amendment granted the concerned magistrate of justice a broader range of powers to ensure the desired balance is achieved. The general principles of this amendment addressed the following issues as major rules: Good Faith, Obligation to Inform, Term of Contract, Abuse of Right, and the Principle of Restitution (Restitutio ad Integrum). The research concludes that the French Civil Code contains regulating rules of the principle of restitution, whereas the UAE Civil Transactions Code has failed to provide a similar unified set of legal principles for the restitution. Interestingly, in Islamic Jurisprudence, clear and unified principles for Restitution exist that are quite different from the principles stated in both the new amendment of the French Civil Code and the UAE Civil Transactions Code.
Khater et al. (Sat,) studied this question.