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Bills Defense Of Comparative Law Research

Posted on:2011-08-18Degree:MasterType:Thesis
Country:ChinaCandidate:J CongFull Text:PDF
GTID:2206360305974062Subject:Civil and Commercial Law
Abstract/Summary:PDF Full Text Request
Bills to limit the right to abuse the right to reduce the debtor's non-legitimate pressure instruments, negotiable nstruments from the long historical development and practice, summed up the principle of defense bills.Negotiable Instruments Law in Geneva, as represented by civil law and the United States, "Uniform Commercial Code" as therepresentative of the common law, the instruments have different characteristics defense.Bills defense will be divided into civillaw on the matter of defense and defense of the people. United States, "Uniform Commercial Code," the provisions of the defenses establishment in the "holder in due course" is defined basis.Based on the size of the rights holder the right to defend subject to the degree of doctrinal defense on the United States Negotiable Instruments Law is divided into "Real defenses" and "Ordinary or personal defenses". This article of the Geneva Law Negotiable Instruments Law and the European and American legal systems are compared, summed up the Geneva law system and the common law defenses in respect of the Notes similarities and differences, to find out where the advanced and suitable for Mainland China, providing a number of legislative models proposal.
Keywords/Search Tags:negotiable instrument counterplea, Geneva law system, Common Law, Comparative study
PDF Full Text Request
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