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Delict is a term in civil law jurisdictions for a civil wrong consisting of an intentional or negligent breach of duty of care that inflicts loss or harm and which triggers legal liability for the wrongdoer; however, its meaning varies from one jurisdiction to another. Other civil wrongs include breach of contract and breach of trust. Liability is imposed on the basis of moral responsibility, i.e. a duty of care or to act, and fault is the main element of liability. The term is used in mixed legal systems such as Scotland, South Africa, Louisiana and the Philippines, but tort is the equivalent legal term used in common law jurisdictions.