The comPaRaTive suRvey of The Bases of faulT-Based liaBiliTy and sTRicT liaBiliTy in ToRT(s) law of iRan and england

Fault can be defined as not behaving like a reasonable man and plays a great role in tort(s) law. General rules of tort(s) law, whether based on fault or not, fall under ”fault-based liability” or ”strict liability”. While fault-based liability is accepted as a principle in tort(s) law of Iran and England, strict liability is an obvious exception to it. This principle in torts law of England, unlike Iran, has not been considered explicitly but can be extracted from case study of different kinds of torts. To sum up, besides differences in legal families of Common Law and Civil Law, similarities in general rules of tort(s) in Iran’s and England’ law are not refutable. However there are disparities in the way these rules are extracted.