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英美财产法中,逆占有制度为一项重要制度,用以惩罚怠于行使权利的所有人及令长期对财产为用益的占有人取得产权。此与大陆法系中的时效制度,无论是消灭时效还是取得时效均有共通之处,然又有异于此。本文就逆占有制度与消灭时效及取得时效分作比较,以明其异同之处。
In the Anglo-American Property Law, the system of reverse possession is an important system for punishing owners who exercise their rights laxly and obtaining property rights over long-term owners who are interested in the property. This and the civil law system of prescription, whether it is to eliminate timeliness or timeliness have something in common, and then different from this. This article compares the system of reverse possession with the eradication of aging and the acquisition of prescription, in order to clarify the similarities and differences.