Application of the United Nations Convention on Contracts for the international sale of goods (CISG) to arab islamic countries: is the CISG compatible with Islamic law principles?

There are some shared characteristics between the United Nations Convention on Contracts for the International Sale of Good (“CISG”) and Islamic law (shari`a). They both remain largely unknown to American lawyers and contain legal principles that are compatible in many ways. The CISG applies to international transactions of goods (personal, family, and household purchases excluded) and aims to facilitate international trade by removing legal barriers. While the Uniform Commercial Code regulates transactions between parties domiciled in the U.S., the CISG governs the sale contracts between traders residing in different CISG contracting states. The author first questions whether the economic backwardness of Arab member states to CISG might have any impact on the legal environment, and whether the drafters of CISG have taken into consideration the economic situation of the Third World. For instance, how could Articles 38, 39 and 40 of the CISG (dealing with the examination of goo