Abstract: In Belgian law, a subjective interpretation of contracts prevails: the common intention of the parties is the vital criterion that governs the construction of agreements. In England the system is more objective, which means the meaning which the document would convey to a reasonable person predominates in matters of contractual interpretation. However, an in-depth analysis of the case Rainy Sky S. A. and others v. Kookmin Bank shows that, in practice, the two systems are more alike than might seem at first sight.
European Review of Private Law