“US law” and “UK law” are fictions — contracts live under the law of a specific place. A rent-review clause that’s standard in England is void in Victoria; Scotland uses irritancy, not forfeiture; Quebec is civil law. Every jurisdiction below carries its own statute and case-law layer in our engine.

Business tenancy security of tenure, unfair terms control, and the modern penalty doctrine.

• Landlord and Tenant Act 1954 Part II (renewal rights and contracting-out)
• UCTA 1977 reasonableness on exclusion clauses
• Dilapidations exposure and schedule-of-condition protection (LTA 1927 s 18)
• Penalty clauses after Cavendish v Makdessi
• Trade Secrets Regulations 2018 for confidentiality terms

A separate mixed legal system — English boilerplate in a Scottish lease is a drafting error our engine flags.

• Irritancy (not forfeiture) with its mandatory statutory notices
• Tacit relocation and notice-to-quit timing
• Real rights under the Leases Act 1449; registration of 20+ year leases
• No doctrine of consideration; 5-year prescription
• LBTT (not SDLT), including three-yearly lease returns

Strict textualism: what you sign is what binds you.

• Plain-meaning enforcement (Osborn v Kemp)
• Anti-reliance clauses and the fraud carve-out (Abry Partners)
• Trade secrets under the DTSA and 6 Del. C.
• UCC Article 2 for goods elements

Federal consumer law composed with state retail-lease regimes that override your lease.

• Australian Consumer Law: non-excludable guarantees, unfair contract terms penalties
• Victoria: 5-year minimum term, ratchet clauses void, land tax non-recoverable (RLA 2003 ss 21/35/50)
• NSW disclosure obligations and bond scheme; Queensland compensation rights
• Penalty doctrine after Andrews and Paciocco
• State-by-state proportionate liability and contracting-out rules

The good-faith revolution applies to every contract — and Quebec is civil law.

• Good faith and honest performance (Bhasin, Callow, Wastech)
• Interest Act s 4 (monthly rates cap at 5%/yr) and the criminal interest rate
• Commercial tenancies statutes and distress rules by province
• Quebec: Civil Code regime, adhesion-contract controls, French-language requirements

Full legal layers, ready for activation.

• South Africa: huur gaat voor koop, Conventional Penalties Act, CPA thresholds, POPIA
• Nigeria: Land Use Act consent requirements, Lagos Tenancy Law advance-rent limits, NDPA 2023

Legal Case Analyst (legalcaseanalyst.com) provides automated, preliminary decision-support analysis. It is not a law firm, does not provide legal advice, and no solicitor/attorney–client relationship is created by its use. For legal advice, consult a licensed practitioner in your jurisdiction — every report can connect you with one. Contact: hello@legalcaseanalyst.com