CONTRACT ENFORCEMENT AND GOOD FAITH OBLIGATIONS: A COMPARATIVE STUDY OF UZBEKISTAN, THE UNITED STATES, AND THE EUROPEAN UNION

Abstract

Few principles in commercial law are as deceptively simple, or as genuinely contested, as good faith. Every major legal system acknowledges it in some form. None of them quite agrees on what it means, when it applies, or how far it reaches. This article examines that disagreement across three legal systems that could hardly be more different in origin and trajectory: the Republic of Uzbekistan, a transition economy that has been systematically modernizing its civil and commercial law framework since 2017; the United States, where good faith sits uneasily between a common law tradition that prizes freedom of contract and a commercial code that quietly imposes it anyway; and the European Union, which has made good faith a cornerstone of its harmonized contract law project while member states continue to apply it in their own ways. The comparison is not offered as an exercise in legal tourism. It is motivated by a practical question that foreign investors, commercial counsel, and Uzbek reform architects are increasingly asking: as Uzbekistan integrates into global commercial networks, how does its developing contractual framework measure up, and where do the gaps remain?