Hello, in my opinion, your way o reasoning is not very complete. Indeed, you should not group all jurisdiction, under civil law family. In my opinion, you should as always use domestic provision for each country. Moreover, although I agree with you regarding the "non-duty" to disclosure in English law, you have forgotten the Sales of Goods Acts, in which s.14 says that it is implied that the good are of satisfactory quality. A car corroded is considered as satisfactory quality ? Even if you consider that it is, you should argue on that, and elaborate more. You way of reasoning is too simple and too vague and is lacking for legal provisions. Still it is only my modest opinion.