مالكيت مافيالذمه در حقوق ايران فرانسه مصر و فقه اماميه

Ownership of Debts in Iranian, French, Egyptian legal Systems and Imamiyya Jurisprudence

According to article 264 of Iranʹ Civil code, ownership of debts happens through the extinction of obligations. The present article deals first with the concept and nature of the ownership of debts, then with its origin and conditions, and finally with its effects in the four legal systems of Iran, France, Egypt, and Shiite jurisprudence. Adopting a comparative approach, the article raises the strong points as well as the weak points of each system concluding that the Iranian legislator is in need of rectification and expurgation of regulations concerning the ownership of debts.