Comparative Property Law

Welcome to the Department of Private Laws seminar series.

Presentation by Professor Andreas Rahmatian, University of Glasgow.

The seminar is open for all interested.

Abstract

In this talk, emphasis will be on personal (moveable) property, not land: in continental European systems, the general principles tend to apply to both areas, while in English law (not Scots law, which has a Romanised property system) land and personal property are (also pedagogically) strictly separated, with the result that personal property law is rather neglected in English law teaching and research. But it is commonplace that, within commercial law, the law of personal property is particularly important, and it is also obvious that commercial law deals with cross-border transactions and business relationships to a large extent.

English personal property law is a very good device to illustrate the special characteristics of property conceptions in English law; in this context land law and the English trust will be discussed as well. This outline exposition of English property law will be contrasted with German property law, a Roman-law based legal system with a particularly high abstraction in its developed property concepts. The comparison and contrast will highlight the differences of these property concepts very well.

Speakers short biography

Andreas Rahmatian is Professor of Commercial Law at the University of Glasgow, Scotland, UK. Originally from Vienna, he obtained a degree and a PhD in law and a second degree in musicology and history there, and continued his studies with an LLM at the University of London. He qualified as a solicitor in London before he became an academic. His research interests comprise commercial law, intellectual property law, property law and property theory, legal history, intellectual history and the law. In 2014-15 he was a Fellow at the Institut d’Études Avancées, Nantes, France. His books include Copyright and Creativity: The Making of Property Rights in Creative Works (2011) and Lord Kames: Legal and Social Theorist (2015).

 

 

Published Feb. 5, 2018 2:54 PM - Last modified Jan. 4, 2024 11:11 AM