The reason the three different law systems have been selected for comparative review is to understand how the reward legal interpretation came to be understood from different legal contexts. For instance, consider the nature of the UK common law system which in essence is an element that is unique to English development. Only some countries influenced by the Anglo Saxon traditions follow the common law system, such as Australia, United States, and India etc. This is a system that derives from statutes and case law. On the other hand, in the case of countries like Germany the civil law system is enforced.
This is also followed in countries such as Austria, Switzerland etc. In terms of contracts legislation China employs the principles of “most closely connected” as is applied in the case of the EU nations. So hence it makes it better to compare it with nations of the EU. UK common law has been the basis for the rise of many national level (commonwealth) legislations and hence UK has been selected as one of the country and Germany has been selected on account of its using the unilateral promise doctrine which is differentiated from the UK’s unilateral contract system. Comparing and understanding the reward system from these two legal contexts is hence interesting. Secondly, while German law, and UK law are developed and established over years, Chinese law system is still in development. The influence of some aspects of German and the Anglo-Saxon law system can be observed in the Chinese legislation and it is for this purpose that the reward system is analyzed from three perspectives.
The research significance and motivation for discussing the nature of the reward advertisement under Chinese legislation lies in the fact that Chinese legislation is ambiguous when considering rewards in the legal standpoint. The selection of rewards advertisement is because ambiguity with respect to the rewards advertisement and critical discussions of it have also been seen in other nations legislation. Hence the research has undertaken a comparative study. Only when studying the legal nature of the reward from a multinational perspective one can fully appreciate how rewards are situated. With countries like the United Kingdom leaning towards considering rewards as a form of offer and countries like German adopting the unilateral doctrine, China seems to adopt a very unsettled standpoint. The manifestation of intention is given importance and based on that the cases are decided. The motivation for this paper is to hence understand how China could adopt a more fixed stance when it comes to considering reward advertisements.