The judge has the power to revise the amount of what is provided for in a penalty clause, in the case where this amount is “manifestly excessive” (art. 1541 Romanian Civil Code). In the legal system French we speak of a “manifestly excessive or derisory amount” (art. 1152 C. civ. français).So it is not only a question of allowing the judge to reduce a penalty, but also of increase it. However, as in other foreign systems, it is n...