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Pacta sunt servanda is the universally accepted notion' that contract promises must be kept and that affirmative actions to ensure satisfactory completion of obligations occurs.2 Even though every legal system emphasizes that breaching a freely negotiated contract is dishonorable3 and requires a remedy, the degree that law insures strict adherence to the precise definition of a contract's original terms has varied across countries.4 This article historically evaluates the relative degree of government interest' in ensuring that contractual relations among independent economic actors maintain integrity by examining both government ideology toward the private sector and the derivative authority of the judiciary as an independent actor that

The Evolution in and International Convergence of the Doctrine of Specific Performance in Three Types of States