Security interests under Chinese law and French law: a study in comparative law
Michel GRIMALDI - Professor (université Paris 2 Panthéon-Assas)
Fréderic BICHERON - Professor (université de Nantes)
Philippe DUPICHOT - Professor (université Paris XII)
Marie GORE - Professor (université Paris 2 Panthéon-Assas)
During the same period, a reform of security law had completed in France, while the Chinese real rights law which has renovated security rights in rem was about to be promulgated in China. This thesis, based on Chinese law and drawing upon a comprehensive study of laws and administrative regulations on the subject, reveals the differences between Chinese and French law and analyze their cause and effect behind similar terms and notions. Grounded on the comparative study, the thesis draws the conclusion that the Chinese system of security rights in rem requires a further reform despite the arrival of new law.