Vorobjeva E.A. The Role of Comparative Law in the Development of the Institute of Transactions Requiring Consent (Approval) of Third Parties

Abstract: The article explains the importance of applying the methods of comparative law to improve national legislation on the example of introducing the institution of transactions requiring consent (approval) of third parties. The comparative characteristic of the norms regulating specified above transaction under the legislation of Germany and the offers, made in the Concept on perfection of the civil legislation in the Russian Federation is given. Are specified similar and distinctive features. The author of the article specifies on that applying the methods of comparative jurisprudence in the study of social problem it is possible to come running to the conscious legislative borrowing of norms and institutes taking into account the features of the national legal system

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