حق حبس در كنوانسيون بيع بين المللي كالا (وين 1980 و حقوق ايران )

The object and principal motive of the contracting parties is the possession of the considerations. To this effect, each party has the right of retention. Each party can relate the performance of the contract of his part to the performance of it by the other party. In the Convention each party has the right of retention against the subject-matter of the contract and for the expenses suffered as a result of preserving the goods. He can also suspend the performance of his obligations. Unlike the Convention, Iranian law does not provide the right of retention against the expenses undertaken for preserving the goods. Nor is the right of suspension accepted as a general rule.