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我国法学界流行的观点认为,在承诺从何时开始生效的问题上,两大法系存在着截然不同的规定,大陆法采纳到达主义,普通法采纳投邮主义。然而,这种观点是错误的。依普通法的规定,口头送达承诺的采了解主义,以电传、传真和电子数据交换等即时送达承诺方式的采到达主义,投邮主义只是合同承诺生效制度中的例外规定,且适用范围在普通法中极其有限。两大法系在承诺生效时间的规定上并无多大区别。
The prevailing view of law circles in our country holds that there are quite different provisions in the two legal systems when promised to come into force. The civil law adopts the principle of arrival and the common law adopts the mail-collecting principle. However, this view is wrong. In accordance with the common law, orally delivered promises of acquisitionist doctrine, telepathy, facsimile and electronic data interchange, etc., are used to reach the doctrine of prompt acceptance, which is only an exception in the contractual undertaking effective system and applies The scope is extremely limited in the common law. There is not much difference between the two legal systems in terms of the promised time.