The Nature of Punitive Compensation and the Extent to Which it Can be Adopted in Jordanian Legislation: A Comparative Study

Dr. Aladdin Abdullah Al Khasawneh
Associate Professor of Civil Law – College of Law, United Arab Emirates University – (Faculty of Law, University of Al Yarmouk, Jordan)


This study deals with the issue of punitive damages as one of the systems adopted in some comparative legislations such as the United States, Canada and Britain, and the position of the French legislature and the French reforms of Civil Code of this system, and the possibility of its introducing in Jordanian legislation. In this study, we have found that punitive damages are a system of a special nature that differs from compensatory damages, and that it has special conditions and different criteria for its evaluation. Its application and criteria for its evaluation should be clearer if the Jordanian legislature tends to organize it with a special text.

Keywords: Compensatory damages, Punitive damages, willfulness, restitution damages, Civil fine.

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