Consignments and the Draft Common Frame of Reference

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Abstract (may include machine translation)

One of the novelties of Book IX of the most recent achievement of European efforts aimed at harmonization of private laws, the Draft Common Frame of Reference, concerns the subjection of some types of consignments to secured transactions law. The paper endeavors to unearth, what main dilemmas are corollary to, and what factors may justify transplantation of a solution from a system based on ‘functional approach’ – Article 9 of the American Uniform Commercial Code – into a law predominantly still based on system thinking (legal dogmatism).
Original languageEnglish
Pages (from-to)358-397
Number of pages40
JournalPravni Zapisi
Volume2
Issue number2
DOIs
StatePublished - 2011

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