American and European models of land ownership restrictions and their impact on the regulation of these relations in Russia
The article analyses the section of the Russian private law system devoted to the restriction of land rights. The modern model of a private easement is analysed, the theory and practice of its application are considered. The Russian experience is compared with the models existing in the European and American legal system. The institute of “neighbourhood law” is investigated. Its models adopted in various foreign countries are considered. Individual elements of legal regulation adopted in foreign countries are proposed for research, the experience of which may be useful for the development of Russian legislation in the field under study.