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Launching a major new research project examining the principles of succession law in comparative perspective, this book discusses the formalities which the law imposes in order for a person to make a testamentary disposal of property.
Among the questions considered are the following:-
The focus is on Europe, and on countries which have been influenced by the European experience. Thus in addition to giving a detailed treatment of the law in Austria, Belgium, England and Wales, France, Germany, Hungary, Italy, the Netherlands, Poland, and Spain, the book explores legal developments in Australia, New Zealand, the United States of America, and in some of the countries of Latin America with a particular emphasis on Brazil. It also includes chapters on two of the mixed jurisdictions - Scotland and South Africa - and on Islamic Law.
The book opens with chapters on Roman law and on the early modern law in Europe, thus setting the historical scene as well as anticipating and complementing the accounts of national history which appear in subsequent chapters; and it concludes with an assessment of the overall development of the law in the countries surveyed, and with some wider reflections on the nature and purpose of testamentary formalities.
Volume II: Intestate Succeession was published in August 2015: isbn 9780198747123