| Popis: |
The purpose of this thesis named 'Civil procedure in continental law and the Anglo- American legal system' is to provide an overview of the regulation of civil procedure in both mentioned systems, to compare them, highlight the most significant differences between them, and give the information about their convergence on international, mainly European level. The reason for the choice of this topic was my interest in the field of Civil Procedure, but also my belief in the benefit of comparisons of various legal orders in favour of improving them. Because of the on-going process of introducing uniform arrangements of some institutes of civil procedure on the European level, it is undoubtedly useful to compare national legislations in some respective countries. The research is based on study of legislation in Czech Republic and Germany as representatives of the continental system and in particular England and Wales as representatives of the Anglo-Saxon system. A shorter chapter is also devoted to U.S. law. There are aims of the thesis, methods of research and brief structure described in the introduction. The second chapter deals with the explanation of basics concepts necessary for proper understanding of the research. The third chapter is devoted to brief sketch of the history of civil procedure in... |
