A Search in Obligation Means and Obligation to Achieve a Certain Result in Law of France and Iran

To resolve the conflict of some articles of civil code in Iran (227 and 226) and France (1137 and 1147) must distinct two types of obligation. Duty to achieve a specific result and duty of best efforts. In obligation of the best effort, promisor has to endeavor in the performance of an activity. He is bound to make such efforts as would be made by a reasonable person of the same kind in the same circumstances. But to the extent that an obligation of a party involves a duty to achieve a specific result, he has to achieve that result.To determining the kind of obligation must be regarded same factor: the issue of contract, the terms of contract, the degree of risk in achieving the result and influence of the other party to performance of the obligation.We can see the extent of notice of Islamic jurisprudence, law of France and Iran to this words and the distinction is effective on behavior of promisor.