Autorentext

Kenneth G C Reid taught law at the University of Edinburgh from 1980 until 2019. He was appointed to the Chair of Property Law in 1994 and to the Chair of Scots Law in 2008. From 1995 to 2005 he served as a Scottish Law Commissioner, where he was responsible for a major programme of reform of land law, subsequently implemented by legislation. His many publications focus on property law, the law of succession, trusts law, legal history, and comparative law.

Jan Peter Schmidt is a Senior Research Fellow at the Max Planck Institute for Comparative and International Private Law in Hamburg and head of its Centre for the Application of Foreign Law. He is a part-time lecturer at the University of Hamburg and the Bucerius Law School Hamburg. He has published widely on matters of contract, family, and notably succession (usually from a comparative or a private international law angle).

Reinhard Zimmermann was Director at the Max Planck Institute of Comparative and International Private Law in Hamburg from 2002 to 2022. He is an Affiliate Professor at the Bucerius Law School and an Honorary Professor at the University of Edinburgh. He has published widely on the law of obligations and the law of succession in a historical and comparative perspective, on the relationship between the English common law and continental civil law, mixed legal systems (in particular Scotland and South Africa), and the harmonization of European private Law.

Klappentext

This volume provides a historical and comparative study of how and by whom the estates of deceased persons are administered, drawing upon the legal traditions of Europe and beyond. The authors examine a representative sample of countries, and offer an overall assessment of the different systems of estate administration.

Inhalt

• Prologue

• 1: Sebastian Lohsse: Administration of Estates in Roman Law

• 2: Thomas RÃ fner: Administration of Estates in Early-Modern Europe

• 3: CÃ(c)cile PÃ(c)rà s: Administration of Estates in France

• 4: Gregor Christandl: Administration of Estates in Italy

• 5: Wilbert D Kolkman: Administration of Estates in the Netherlands

• 6: Sergio Cámara Lapuente: Administration of Estates in Spain

• 7: Jan Peter Schmidt: Administration of Estates in South America

• 8: Christiane Wendehorst: Administration of Estates in Austria

• 9: Lajos VÃ(c)kás: Administration of Estates in Hungary

• 10: Reinhard Zimmermann: Administration of Estates in Germany

• 11: Elspeth Christie Reid: Administration of Estates in Russia

• 12: Neil Jones: Administration of Estates in English Law before the Wills Act 1837

• 13: Roger Kerridge: Administration of Estates in England and Wales

• 14: Kenneth G C Reid: Administration of Estates in Scotland

• 15: Prue Vines and Nicola Peart: Administration of Estates in Australia and New Zealand

• 16: Alexandra Popovici and Lionel Smith: Administration of Estates in Canada

• 17: Ronald J Scalise Jr: Administration of Estates in the United States of America

• 18: François du Toit: Administration of Estates in South Africa

• 19: Thomas Eeg: Administration of Estates in Norway

• 20: Knut Benjamin Pißler: Administration of Estates in the People's Republic of China

• 21: Reinhard Zimmermann and Jan Peter Schmidt: Administration of Estates in Historical and Comparative Perspective

• Epilogue