Comparative Study on Guarantee Law: Taking the guarantee laws of Germany, France, Switzerland, Italy, the United Kingdom, and China as the research objects

Author: Fei Anling
Publisher:
Publish Date: 2004-03-01
Features: The book's features: , The main basis of this book is the Civil Codes and related laws of EU countries. The author has not examined the legal systems of all EU countries but has selected some representative countries such as Germany, France, Switzerland, Italy, and the United Kingdom as the objects of study. Because their respective Civil Codes are distinctive in terms of system and theory, they can fully serve as representatives of the Civil Law countries, while the United Kingdom is a major representative country of the Common Law system. In the discussion, while distinguishing the two legal systems in principle, some content is also compared together. Second, in terms of research methods, a combination of differentiated analysis and comprehensive analysis is adopted. Because the five countries involved can basically be divided into three legislative models. Germany and Switzerland of the Civil Law system belong to the same category, France and Italy are similar, and belong to the Common Law system, the United Kingdom is a separate entity, but there are differences within the same category, and similarities within the different categories, but the book's features: , The main basis of this book is the Civil Codes and related laws of EU countries. The author has not examined the legal systems of all EU countries but has selected some representative countries such as Germany, France, Switzerland, Italy, and the United Kingdom as the objects of study. Because their respective Civil Codes are distinctive in terms of system and theory, they can fully serve as representatives of the Civil Law countries, while the United Kingdom is a major representative country of the Common Law system. In the discussion, while distinguishing the two legal systems in principle, some content is also compared together. Second, in terms of research methods, a combination of differentiated analysis and comprehensive analysis is adopted. Because the five countries involved can basically be divided into three legislative models, Germany and Switzerland of the Civil Law system belong to the same category, France and Italy are similar, and belong to the Common Law system, the United Kingdom is a separate entity, but there are differences within the same category, and similarities within the different categories, but