The recognition and treatment of title retention in the legal systems of the united kingdom, vietnam and related jurisdictions a compartive study
➤ Gửi thông báo lỗi ⚠️ Báo cáo tài liệu vi phạmNội dung chi tiết: The recognition and treatment of title retention in the legal systems of the united kingdom, vietnam and related jurisdictions a compartive study
The recognition and treatment of title retention in the legal systems of the united kingdom, vietnam and related jurisdictions a compartive study
Lancaster UniversityLaw SchoolTHE RECOGNITION AND TREATMENT OF TITLE RETENTION IN THE LEGAL SYSTEMS OF THE UNITED KINGDOM, VIETNAM AND RELATED JURISDI The recognition and treatment of title retention in the legal systems of the united kingdom, vietnam and related jurisdictions a compartive study ICTIONS: A COMPARATIVE STUDYHien TrinhPresented for the degree of Doctor of PhilosophyLancaster University20181DECLARATIONI, Hien Trinh, do hereby declare that this submission is my own work. 1 have not submitted it in substantially the same form towards the award of any other degree or qualificatio The recognition and treatment of title retention in the legal systems of the united kingdom, vietnam and related jurisdictions a compartive study n. It has not been written or composed by any other person and all sources have been appropriately referenced.2ACKNOWLEDGEMENTI have benefited from thThe recognition and treatment of title retention in the legal systems of the united kingdom, vietnam and related jurisdictions a compartive study
e assistance and endorsement of numerous people for over the last four years for the completion of this thesis.First and foremost. I wish to thank my Lancaster UniversityLaw SchoolTHE RECOGNITION AND TREATMENT OF TITLE RETENTION IN THE LEGAL SYSTEMS OF THE UNITED KINGDOM, VIETNAM AND RELATED JURISDI The recognition and treatment of title retention in the legal systems of the united kingdom, vietnam and related jurisdictions a compartive study ot have been possible at the very beginning without the support, encouragement and patience of Professor David Milman. He not only provides helpful and valuable comments and instructions for my research but also accepts my status of "away” student. His role is vital and decisive, and I am honoured t The recognition and treatment of title retention in the legal systems of the united kingdom, vietnam and related jurisdictions a compartive study o be his student.I am grateful to the Lancaster University for providing me with the facilities for carrying out this research, special thanks to theThe recognition and treatment of title retention in the legal systems of the united kingdom, vietnam and related jurisdictions a compartive study
Vietnamese Ministry of Education They granted me the full scholarship to pursue the Ph D. study in England for three years.I would like to take the opLancaster UniversityLaw SchoolTHE RECOGNITION AND TREATMENT OF TITLE RETENTION IN THE LEGAL SYSTEMS OF THE UNITED KINGDOM, VIETNAM AND RELATED JURISDI The recognition and treatment of title retention in the legal systems of the united kingdom, vietnam and related jurisdictions a compartive study could not be done. Finally. I would like to dedicate this thesis to my father, who is always proud of me. and to my children with a hope that It could be an inspiration 111 then life.3ABSTRACTTitle retention functionally serves as a security device for ensuring the payment of the purchase price in The recognition and treatment of title retention in the legal systems of the united kingdom, vietnam and related jurisdictions a compartive study a sales contract, but not all jurisdictions recognize it as a security interest. The research aims to compare the recognition and treatment of title rThe recognition and treatment of title retention in the legal systems of the united kingdom, vietnam and related jurisdictions a compartive study
etention in Vietnam, England, France, the United States and Australia. It examines the issues arising in Vietnam concerning the existing law of title Lancaster UniversityLaw SchoolTHE RECOGNITION AND TREATMENT OF TITLE RETENTION IN THE LEGAL SYSTEMS OF THE UNITED KINGDOM, VIETNAM AND RELATED JURISDI The recognition and treatment of title retention in the legal systems of the united kingdom, vietnam and related jurisdictions a compartive study d comparative analysis methods with the aid of a critical outlook and a discussion on the legal transplant.It is found that English law insists on the formalism approach that does not accept title retention to the original goods as a security interest. It raises the unexpected impact on the Sale of The recognition and treatment of title retention in the legal systems of the united kingdom, vietnam and related jurisdictions a compartive study Goods Act after the FG Wilson (Engineering) Ltd V John Holt & Co (Liverpool) Ltd-’and PST Energy 7 Shipping LLC V ƠIV Bunker Malta Ltd- rulings. VietnThe recognition and treatment of title retention in the legal systems of the united kingdom, vietnam and related jurisdictions a compartive study
amese law adopts the French law approach that treats title retention as a security interest, but it is merely a seller-based securityinterest that excLancaster UniversityLaw SchoolTHE RECOGNITION AND TREATMENT OF TITLE RETENTION IN THE LEGAL SYSTEMS OF THE UNITED KINGDOM, VIETNAM AND RELATED JURISDI The recognition and treatment of title retention in the legal systems of the united kingdom, vietnam and related jurisdictions a compartive study and increasingly-accepted model of the law on secured transactions. It introduces the concept of purchase-money security interest that includes the title retention arrangement. The functionalism, unitary approach and the notice filing system under the Article 9 offer a comprehensive treatment of a The recognition and treatment of title retention in the legal systems of the united kingdom, vietnam and related jurisdictions a compartive study purchase-money security interest as the exception of the general security interest.The findings suggest that even though Article 9 is currently a goodThe recognition and treatment of title retention in the legal systems of the united kingdom, vietnam and related jurisdictions a compartive study
model in this area, the import of this model may encounter some resistance from the angle of legal culture and legal practice. From the Vietnamese peLancaster UniversityLaw SchoolTHE RECOGNITION AND TREATMENT OF TITLE RETENTION IN THE LEGAL SYSTEMS OF THE UNITED KINGDOM, VIETNAM AND RELATED JURISDI The recognition and treatment of title retention in the legal systems of the united kingdom, vietnam and related jurisdictions a compartive study e considering adopting a unitary functionalism law of secured transactions.* 2013] EWCA Civ 1232, [2014] 1 WLR 23652 [2016] UKSC 23; [2016] AC 10344CONTENTSDECLARATION..................................................2ACKNOWLEDGEMENT..........................................3ABSTRACT................ The recognition and treatment of title retention in the legal systems of the united kingdom, vietnam and related jurisdictions a compartive study .................................4CONTENTS.................................................5LIST OF ABBREVIATIONS.....................................The recognition and treatment of title retention in the legal systems of the united kingdom, vietnam and related jurisdictions a compartive study
....7CHAPTER 1 INTRODUCTION.......................................81.1THE ISSUE..-„....„-„----... „------------- „---..... „---------- „...81.2ResearcLancaster UniversityLaw SchoolTHE RECOGNITION AND TREATMENT OF TITLE RETENTION IN THE LEGAL SYSTEMS OF THE UNITED KINGDOM, VIETNAM AND RELATED JURISDILancaster UniversityLaw SchoolTHE RECOGNITION AND TREATMENT OF TITLE RETENTION IN THE LEGAL SYSTEMS OF THE UNITED KINGDOM, VIETNAM AND RELATED JURISDIGọi ngay
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