Comparative Study on Guarantee Law (with 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 features of this book are as follows: This book is primarily based on 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 ones, such as Germany, France, Switzerland, Italy, and the United Kingdom, as the objects of study. This is because the civil codes of each of these countries are distinctive in terms of their systems and theories, making them fully representative of the civil law countries. The United Kingdom, on the other hand, is a major representative country of the common law system. In the discussion, while distinguishing between 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. This is because the five countries involved can basically be divided into three legislative models. Germany and Switzerland, which belong to the civil law system, are of the same type, while France and Italy are similar and belong to the common law system, with the United Kingdom forming its own category. However, there are differences within the same type and similarities within different types, but the book features: The features of this book are as follows: This book is primarily based on 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 ones, such as Germany, France, Switzerland, Italy, and the United Kingdom, as the objects of study. This is because the civil codes of each of these countries are distinctive in terms of their systems and theories, making them fully representative of the civil law countries. The United Kingdom, on the other hand, is a major representative country of the common law system. In the discussion, while distinguishing between 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. This is because the five countries involved can basically be divided into three legislative models. Germany and Switzerland, which belong to the civil law system, are of the same type, while France and Italy are similar and belong to the common law system, with the United Kingdom forming its own category. However, there are differences within the same type and similarities within different types, but