The Scandinavian law of obligations – and of contracts – is a part of the law with old traditions

From a Norwegian perspective, a modern law of obligations and of contracts was launched in the early 1850s, with the publication of a textbook incorporating the existing statutes and court decisions. By the 1870s, the law of obligations was a well-established discipline, both academically and in legal practice. The law of obligations was strengthened at the same time by the establishment on a governmental level of Scandinavian cooperation on legislation in the field of the law of obligations. One of the best known fruits of this is the joint Scandinavian Sales of Goods Act (1905–1907). It was not, however, a wholly Scandinavian invention, but was to a large extent a pragmatic simplification of concepts from English, French and German law. It can be noted that this pragmatic legislation was one of the cornerstones for CISG; it was very familiar to Ernst Rabel, who had initiated the publication of a German version of Tore Almén's extensive commentary on the Sales of Goods Act.

Thus, Scandinavian law has long been regarded as a separate entity from English, French and German law, a law family of its own. The law of contracts is the main core of Scandinavian private law, and textbooks and court decisions from one of the countries is regarded more or less as on the same level as internal sources of law.