Germany has taken a much stricter approach than the United States to cases involving a breach of the duty of oversight, even though the German business judgment rule formally requires a showing of the same elements as the American one.
Source quote, verbatim
For instance, Germany has taken a much stricter approach to cases involving a breach of the duty of oversight.
From
Kaal, A Comparative Perspective on the Limitations of the Duty of Oversight – A Comment on Lisa Fairfax (2013), A Comparative Perspective on the Duty to Monitor, p. 5 · source PDF
Cite as
Kaal, A Comparative Perspective on the Limitations of the Duty of Oversight – A Comment on Lisa Fairfax (2013)
Holds when
comparison of German and Delaware corporate law
Classification
empiricalsupport: arguedcorporate-governance
Related claims
supersedeskaal:claim:1558614-006 Although the business judgment rule is articulated differently in the two countries and German law leaves some...
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