Transfer of Movables in German, French, English and Dutch Law

Download or read book Transfer of Movables in German, French, English and Dutch Law written by Lars Peter Wunibald van Vliet and published by . This book was released on 2000 with total page 270 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.