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Author: Wolfgang Faber
Publisher: Walter de Gruyter
ISBN: 386653700X
Category : Law
Languages : en
Pages : 281
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Book Description
Comparative research in the area of property law is gaining importance. Against the background of the current discussion of developing model rules, aimed at facilitating European private law harmonisation, and of ongoing law reform projects in a number of EU Member States, this volume addresses key issues in the field of the transfer of corporeal movable property.
Author: Wolfgang Faber
Publisher: Walter de Gruyter
ISBN: 386653700X
Category : Law
Languages : en
Pages : 281
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Book Description
Comparative research in the area of property law is gaining importance. Against the background of the current discussion of developing model rules, aimed at facilitating European private law harmonisation, and of ongoing law reform projects in a number of EU Member States, this volume addresses key issues in the field of the transfer of corporeal movable property.
Author: Lars Peter Wunibald van Vliet
Publisher:
ISBN:
Category : Conditional sales
Languages : en
Pages : 270
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Book Description
The subject-matter of this book is the transfer of movable property in German, French, English and Dutch law. Of particular importance is the division into the three main types of transfer system: the causal consensual system, the causal tradition system and the abstract tradition system. Here two dividing lines intertwine: the distinction between causal and abstract systems and the distinction between consensual and tradition systems. Often the existence of three different transfer systems is seen as a complicating factor in harmonizing European private law. Yet, the book demonstrates that the division between consensual systems and tradition systems and the division between causal and abstract systems are not unbridgeable.
Author: Janeen M. Carruthers
Publisher: Oxford Private International L
ISBN: 9780199271474
Category : Law
Languages : en
Pages : 0
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Book Description
This book provides a detailed and up-to-date exposition of English and Scottish rules of choice of law in inter vivos transfers of property. It traces the development of the lex situs rule, and its application to inter vivos dealings with immovable property, tangible movable property(including the special case of cultural property), and intangible movable property (including indirectly held securities).The author offers two alternative models of suggested choice of law rules in property, introducing a greater degree of flexibility into choice of law rules in property, and formulates even-handed solutions to the complex problems of space, time and policy which arise in this area of the conflict oflaws.
Author: Danny Busch
Publisher: Cambridge University Press
ISBN: 1139476351
Category : Law
Languages : en
Pages : 481
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Book Description
The focus of this book, the legal situation created when an agent acts without authority, is one of the most important issues in agency law. The analysis is divided into three sections: apparent authority, ratification and the liability of the falsus procurator. Adopting a unique comparative perspective, the contributions are drawn from many different legal systems, providing the opportunity for analysis of the European common law/civil law divide. The analysis extends beyond Europe, however, taking into account the mixed legal system of South Africa, as well as the United States. Finally, there is a useful consideration of the Principles of European Contract Law and the UNIDROIT Principles of International Commercial Contracts 2004. This study will be an invaluable guide for those interested in the study of comparative law, international practitioners and those interested in the harmonisation of European Private Law.
Author: Bashkim Preteni
Publisher:
ISBN: 9783631820377
Category :
Languages : en
Pages : 280
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Book Description
Author: Eva-Maria Kieninger
Publisher: Cambridge University Press
ISBN: 1139454757
Category : Law
Languages : en
Pages : 827
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Book Description
For every transnational lawyer, it is vital to know the differences between national secured transactions laws. Since the applicable law is determined by the place where the collateral is situated, it may change when movables are brought from one state to another. Introductory essays from comparative lawyers set the scene. The book then presents a survey of the law relating to secured transactions in the member states of the European Union. Following the Common Core approach, the national reports are centred around fifteen hypothetical cases dealing with the most important issues of secured transactions law, such as the creation of security rights in different business situations, the relationship between debtor and secured creditor, the nature of the creditor's rights and their enforcement as against third parties. each case is followed by a comparative summary. A general report evaluates the possibilities of European harmonisation in the field of secured transactions law.
Author: Maebh Harding
Publisher: Routledge
ISBN: 1134594259
Category : Law
Languages : en
Pages : 368
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Book Description
Conflict of Laws provides a straight-forward and accessible introduction to English private international law. It examines the jurisdiction of English courts (and whether their judgments are enforced and recognized overseas) and the effect of foreign judgments in England. Recent years have seen an increased ‘Europeanization’ of English Law which has transformed the subject and this fifth edition takes into account key recent developments and regulations including proposed changes to Brussels I, Rome II, The Maintenance Regulation, Rome III, the proposed Rome IV and the proposed Succession Regulation. Harding provides students with a clear understanding using pedagogic methods such as; Key Issues checklists at the start of every chapter to help track important points for further study Figures are used to aid understanding through visual learning Further Reading is included at the end of every chapter to enourage and support additional study Further developments addressed in the fifth edition include: • The use of common law doctrines in EU cases such as West Tankers. • The EU imperative for family relationships to be recognized across the EU in the context of citizen’s rights. • Civil Partnerships and recognition of same sex partnership. • Rome III, Rome IV and the distinction between maintenance and matrimonial property. • Adoption, Parental Responsibility and International Child Abduction • Surrogacy and Assisted Reproduction Conflict of Laws is an ideal choice for undergraduate and postgraduate students seeking a comprehensive yet accessible introduction to private international law.
Author: Sjef van Erp
Publisher: Bloomsbury Publishing
ISBN: 1847319823
Category : Law
Languages : en
Pages : 1252
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Book Description
This casebook presents a deep comparative analysis of property law systems in Europe (ie the law of immovables, movables and claims), offering signposts and stepping stones for the reader wishing to explore this fascinating area. The subject matter is explained with careful attention given to its history, foundations, thought-patterns, underlying principles and basic concepts. The casebook focuses on uncovering differences and similarities between Europe's major legal systems: French, German, Dutch and English law are examined, while Austrian and Belgian law are also touched upon. The book combines excerpts from primary source materials (case law and legislation) and from doctrine and soft law. In doing so it presents a faithful picture of the systems concerned. Separate chapters deal with the various types of property rights, their creation, transfer and destruction, with security rights (such as mortgages, pledges, retention of title) as well as with harmonising and unifying efforts at the EU and global level. Through the functional approach taken by the Ius Commune Casebooks this volume clearly demonstrates that traditional comparative insights no longer hold. The law of property used to be regarded as a product of historical developments and political ideology, which were considered to be almost set in stone and assumed to render any substantial form of harmonisation or approximation very unlikely. Even experienced comparative lawyers considered the divide between common law and civil law to be so deep that no common ground - so it was thought - could be found. However economic integration, in particular integration of financial markets and freedom of establishment, has led to the integration of particular areas of property law such as mortgage law and enforceable security instruments (eg retention of title). This pressure towards integration has led comparative lawyers to refocus their interest from contract, tort and unjustified enrichment to property law and delve beneath its surface. This book reveals that today property law systems are closer to one another than previously assumed, that common ground can be found and that differences can be analysed in a new light to enable comparison and further the development of property law in Europe.
Author: Michele Graziadei
Publisher: Edward Elgar Publishing
ISBN: 1785369164
Category : Law
Languages : en
Pages : 515
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Book Description
Comparative Property Law provides a comprehensive treatment of property law from a comparative and global perspective. The contributors, who are leading experts in their fields, cover both classical and new subjects, including the transfer of property, the public-private divide in property law, water and forest laws, and the property rights of aboriginal peoples. This Handbook maps the structure and the dynamics of property law in the contemporary world and will be an invaluable reference for researchers working in all domains of property law.
Author: Foote
Publisher:
ISBN:
Category : Conflict of laws
Languages : en
Pages : 620
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Book Description
