Abstract: Although civil law and common law show growing convergence in the area of contract and tort law, still a large divergence can be seen in the area of property law. The most important explanation for this divergence is the historical development of these two legal systems. However, as a result of economic integration unification of property law seems to become unavoidable, especially with regard to security interests. In this article property law is analysed from a comparative and historical viewpoint, taking into account the close connection between the law and economic reality.
European Review of Private Law