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property law , principles, policies, and rules by which disputes over property are to be resolved and by which property transactions may be structured. What distinguishes property law from other kinds of law is that property law deals with the relationships between and among members of a society with respect to “ things .” The things may be tangible. such as land or a factory or a diamond ring, or they may be intangible. such as stocks and bonds or a bank account. Property law, then, deals with the allocation, use, and transfer of wealth and the objects of wealth. As such, it reflects the economy of the society in which it is found. Since it deals with the control and transfer of wealth between spouses and across generations, property law also reflects the family structure of the society in which it is found. Finally, because it deals with such fundamental issues as the economy and the structure of the family, property law also reflects the politics of the society in which it is found.

This article outlines the major systems of property law that have existed historically and that exist today. The principal focus is on the two major Western systems of law that have become dominant in the industrialized world: the Anglo-American system, derived from the English common law. and the civil law system, which was developed on the European continent on the basis of Roman law. The article will also compare Anglo-American property law with its counterpart in various civil law (i.e. law based on Roman law rather than English common law) countries, including Germany and modern China. Special attention will be given to the rules of property law in countries that, because of their socialist political system. did not recognize private ownership of property. Russia and Romania will be used as the main examples.