目次一、引言二、比较法上的占有三、未来民法典中的占有概念一、引言民法典编纂工作已经启动,这是我国私法体系构建过程中的里程碑事件。民法典编纂不仅是在各单行法基础上的整合活动,也是一个补充完善现行法,将司法实践经验成文化的契机。我国在制定民事单行法的过程中,或由于实践经验不足,理论研究薄弱,部分问题尚未规定;或由于考虑不够成熟,立法 I. INTRODUCTION II. The Possession of Comparative Law III. The Concept of Possession in the Future Civil Code I. Introduction Codification of the Civil Code has been started, which is a milestone in the process of constructing the system of private law in our country. The compilation of civil code is not only an integrated activity on the basis of each one-line law, but also an opportunity to supplement and perfect the existing law and to codify the judicial practice experience. In the course of formulating the civil law, or because of the lack of practical experience, theoretical research is weak, some of the problems have not yet been stipulated; or because the consideration is not mature enough, the legislation