A significant change of circumstances: the Russian approach in the context of foreign experience

he concept of a significant change in circumstances is interpreted differently depending on the legal system. In the European tradition of contract law, the doctrine of the essential circumstances of the expression of will is built up as part of the section on the limitations of the will to the transaction. Modern trends converge towards the adaptation of the contract to the changed circumstances. There is also the English doctrine of "frustration of contract", which allows you to terminate contractual relations after the conclusion of a contract of a cardinal and unforeseen change in external conditions. The study in this paper presents a review of the criteria and consequences of applying the doctrine of a significant change in circumstances based on the theories of foreign countries and domestic judicial practice.