Comparative Study of Damage Caused by Damage in Iranian Law and International Sale of Goods Convention

Compensation is one of the key topics in civil liability and contract law, which is applied in different legal systems in different ways. In Iranian law, compensation is determined mainly based on the general rules of civil responsibility and jurisprudence principles; The most prominent goal of compensation is to satisfy the injured party and restore the injured party's previous status .In international systems, including the Convention on the International Sale of Goods (CISG), more specific methods are provided to compensate for damages caused by breach of contract. This convention examines methods of compensation in Articles 74 to 77 and provides the injured party with the possibility of claiming the difference in price between the original contract and the replacement contract. Articles 75 and 76 of the Convention contain methods for compensation for damages resulting from the termination or breach of a contract of sale. Using a descriptive-analytical method, this study conducts a comparative study of Iranian regulations and the Convention on the International Sale of Goods in the field of compensation for damages and analyzes the implementation challenges of these regulations. The results of the study show that the compensation regulations in Iranian law are in some cases consistent with international standards, but in some aspects, such as the acceptance of loss of profit and the method of determining the amount of damages, they are subject to ambiguity and implementation limitations. Finally, suggestions are presented for amending domestic laws and better compliance with international standards.