Purpose: The article analyzes the concepts used in the institute of compensation for moral damage in Russia and the countries of the Anglo-Saxon law system.
Methodology: Various general scientific methods and the methods of logical cognition are used in the work: analysis and synthesis, system-ic, functional and formal-logical approaches. The development of conclusions was facilitated by the application of formal-legal and comparative-legal methods.
Result: The article reveals the grounds for compensation for moral damage in Russia, England, and the USA. The author refers to the similarities and differences of the institute of compensation for moral damage in these countries. The conclusion about the need for unification of the institution in various legal systems.
Applications: This research can be used for the universities, teachers and education students.
Novelty/Originality: In this research, the model of the compensation of moral damage in Russia and the Anglo-Saxon legal system countries is presented in a comprehensive and complete manner.
The article is devoted to the application of the class action institution in different countries and legal systems. The article deals with questions about the meaning of the institute of class action, interests protected with the help of it, positive and negative aspects of this institution are estimated. In addition, the article analyses characteristics and conditions of presentation of the class action. The research was conducted by using general scientific and specific methods of research including the analogy method, formal logical and comparative law methods. As a result, the Russian institute of class action, by its characteristics, is classified as a continental model. The analysis of the latest changes in Russian legislation reveals, at the same time, a tendency to converge with the Anglo-Saxon model of private class action.
This is an Open Access article distributed under the terms of the Creative Commons Attribution-Noncommercial 4.0 Unported License, permitting all non-commercial use, distribution, and reproduction in any medium, provided the original work is properly cited.
Bankruptcy is the legitimate procedure by which monetarily troubled firms, people, and sporadically governments settle their obligations. The insolvency procedure for firms assumes a focal job in financial aspects, since rivalry drives the most wasteful firms bankrupt, subsequently raising the normal proficiency level of those remaining. This study provides a comparative analysis of the most significant aspects of bankruptcy for individuals in Russia and the United States. The objective of the study was to determine the conditions involved in declaring a citizen insolvent in US and Russian law, for which we studied the ways of filing applications in these countries, as well as some methods of abuse by creditors that reduce the effectiveness of the bankruptcy institu-tion, and the ways to minimize them. Based on the results of the analysis, proposals were made to improve the legislation that governs people's bankruptcy. These proposals are based on the positive experience of the United States in the field of legal regulation of insolvency institutions.
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