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Obligation and Schuldrecht

From Civil law

Contract and obligationsBasic ideas

What it means

In civil law, an obligation is a legal bond between two people, in which one (the debtor) owes something to the other (the creditor). The 'law of obligations' covers contracts, torts and unjust enrichment together.

Why it travels badly

In English, 'obligation' is a general word for any duty. In civil law it is a technical term. In German, Schuld means both debt and guilt, which is why the law of obligations is Schuldrecht.

How other systems say it

France

obligation / droit des obligations

A technical term: the bond itself, whether from contract, fault or the law.

Germany

Schuldverhältnis / Schuldrecht

Schuld means debt as well as guilt, so the word hides a legal and a moral idea in one.

United Kingdom

law of contract, tort and restitution

English law divides the same ground into separate subjects.

Tip for translators and students

Do not translate 'law of obligations' as 'duty law'. Use the term and explain that it covers contract, tort and unjust enrichment.

Related: Tort and delict, Consideration

Updated October 2026. Spotted a mistake? Tell us.

TheLawToKnow Tools’s glossary is an educational overview of the main differences between legal systems. It is not legal advice.