PBL
Comparative legal studies are important in order to gain an firmer understanding of legal concepts in individual jurisdictions and to related them to more-universal concepts, such as that of responsibility and just compensation, which concern us all, all over the world.
In aviation terms, will you agree with me that the Warsaw Convention as modified by the Montreal Convention are the prevailing authorities?.
Both are universal.
In both cases, as regards transported passengers.
The topic becomes a little more complicated when there are victims on the ground, such as happened at Gonesse. And that is not an unlikely scenario.
Warsaw and Montreal cannot apply to victims on the ground, obviously, because there never was a contract of transport between the carrier and the victim,
I know a little bit about how the insurance fandango worked, but I can not be too specific, for that would breach my confidentiality undertakings.
Air France was indemnified for the loss of the airframe within days.
The "ayants droit" or inheritors for non French speaking readers, of passengers, were offered indemities according to Warsaw and Montreal, by Air France, with, of course their insurers behind them.
Those indemities were by and large accepted. Acceptance included an undertaking that no further process could be undertaken. (That is not the same phenomenom as subrogation, as mentioned elsewhere, but the distinction is not so important here)