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Force majeure
A continental law concept meaning occurrences of a type (e.g. acts of God) which are outside the control of the parties and which justify the non-performance of obligations under a contract (without the contract itself having to set this out).
Under English law, nonperformance of a contract for reasons which are not specified in the contract but which are outside the control of the parties, is justified if the contract is "frustrated".
This is a much narrower concept than the continental concept of force majeure.
For this reason, many English law contracts contain force majeure clauses, specifically allowing non-performance in circumstances which would not amount to frustration.
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