عنوان مقاله [English]
< p >Abstract
In this study, attempts were made to understand the views of the two legal systems of Iran and the European Union on the revocation and feasibility of it in the donation. The purpose of this study, while familiarizing with the draft EU civil law, was to examine the comparative approach of the revocation and the effects of it in two systems. Finally, while suggesting an opinion on the Iranian and European legislature''s approach and its cases, we have achieved the result that, despite the similarity in the target, Due to the acceptance of the principle of the ability to revocation, the Iranian legislators have made exceptions to the impossibility of revocation; While in the EU law, due to adopting a non-revocation approach, the cases of revocation have been established somewhat limited but reasonable including: Ingratitude, Impoverishment and Change of essential circumstances of the time of concluding the contract after the hangover. This comparative approach to the subject has been widespread in the field of action and opinion and, while imparting the minds of the Iranian legislator, can fill some legal vacuum or bring about a reform of the law.
Revocation, Donation, Donor, Donee, Dcfr.