General Concepts of Private Law Relating to Private Property in the Civil Code of the Russian Federation and in the Civil Code of Quebec

in Review of Central and East European Law
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Abstract

The paperidentifies some notable features on general private law ordering contained in the Civil Code of the Russian Federation. It does so by contrasting these provisions with similar articles and doctrine from the Civil Code of Quebec. The author points out several unique features of the Russian code and speculates on some of the potential implications of these features for private law ordering. These comments are meant to stimulate discussion and comparison, and are not meant to be exhaustive in either their descriptive content or substantive analysis. The Russian code convers similar conceptual territory as the Quebec code; thus, the organizing concepts are analogous. It is therefore not surprising that the animating themes of private laaw in the civilist tradition, major distinctions such as patrimonial and extra-patrimonial rights, real and personal rights, and various sub categories, find expression in the Russian code. The elaboration of these ideas is generally much extensive in the Russian code that in the Quebec code, although the iteration in the latter is arguably more concise, clear and coherent.

General Concepts of Private Law Relating to Private Property in the Civil Code of the Russian Federation and in the Civil Code of Quebec

in Review of Central and East European Law

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