两大法系代理制度的比较研究

代理制度是大陆法系与英美法系所共有的一项法律制度,与此同时,在两大法系的区别中,没有哪一个分支的法学理论的差异像代理这样大.由于两大法系法律文化、历史传统、思维方式以及其他社会经济因素的不同,致使各个国家赋予它的含义不完全一样.本文通过对两大法系代理制度的历史发展、两大法系关于代理的规定的比较研究,揭示其差异的原因,并对我国的代理制度进行评价.

Comparative Research on Agency's System of Two Fundamental Laws

System law of continent department and Great Britain American and French one a item of legal systems that department have agency in alls, Meanwhile, in fundamental laws and principles the differences of departments, have which the law science the differences of theories of branch looks like and acts as agent so heavily, Because the legal culture, historical tradition, difference of the mode of thinking and other social economic factors of department of two fundamental laws and principles, Cause countries give it totally the same meaning. This text through at fundamental laws and principles department act for the historical developments of system, department of fundamental laws and principles provision on acting as agents relatively study, It announces its the reasons of difference and agency system in our country appraise.