A Comparative Study On The Proprietary Rights Retention System

This dissertation studies the basic theory of proprietary rights retention system and its legislation and practice in some important countries .The author puts forward his imagination in formulating China's real rights law , perfecting warrant system legislative selecting the registration antagonist ,and establishing the announcement and registration system.Chapter I analysis the legislation and practice of proprietary rights retention system ,and its rationality in China's Real Rights law .At the same time ,puts forward China's legislative selection about the system .Chapter II studies the main types of proprietary rights retention provision, especially inquires into its legal nature, constitution and its legal mechanism.Chapter III and chapter IV are very important. In the transaction that adds proprietary rights retention provision, as soon as the proprietary rights retention become effective, it takes place effect to the exterior and the Interior .To the interior, it refers to the restraint between the buyer and the seller. To the exterior , It refers to the effect to the others .In the two chapters, the interior and exterior effect of proprietary rights retention are discussed deeply . In concrete , the two chapters mainly focuses on protecting the bought by two person ,the terms that the buyer exercises his dissolution rights for protecting his expectant, the effect to the specified thing and the received thing from transfer ,when the seller fetched it .At last ,the author puts forward some relative view about china's legislation .Chapter V analysis some countries' registration system ,announcement and registration system about proprietary rights retention researches its legislative selection ,and puts forward his own ideas on china's announcement and registration system .