西方国家旅游合同立法模式选择及其借鉴

On the Choice of Legislative Modes of Tourism Contracts in Western Countries and Its Enlightenment

本文通过对不同国家旅游合同立法体例模式及其具体内容的比较研究,分析了旅游合同不同立法体例选择的内在根源。探讨了中国旅游合同立法在借鉴国外先进经验基础上可供选择的路径,认为将旅游合同立法置于《合同法》是最佳选择。

Through the comparative research of legislative modes in different countries and their concrete contents, the paper analyzes the intrinsic source of different choices of legislative modes. It also discusses the route that can be chosen in China based on referring to advanced legislative experience abroad and holds that the best choice is to include tourism contract into Contract Law.