civil law jurisdictions treat contracts differently in a number of respects, with a more interventionist role for the state in both the formation and enforcement of contracts. compared to common law jurisdictions, civil law systems incorporate more mandatory terms into contracts, allow greater latitude for courts to interpret and revise contract terms and impose a stronger duty of good faith, but are also more likely to enforce penalty clauses and specific performance of contracts. they also do not require consideration for a contract to be binding. in france, an ordinary contract is said to form simply on the basis of a "meeting of the minds" or a "concurrence of wills". germany has a special approach to contracts, which ties into property law. their 'abstraction principle' ("abstraktionsprinzip") means that the personal obligation of contract forms separately from the title of property being conferred. when contracts are invalidated for some reason (e.g. a car buyer is so drunk that he lacks legal capacity to contract) the contractual obligation to pay can be invalidated separately from the proprietary title of the car. unjust enrichment law, rather than contract law, is then used to restore title to the rightful owner.