Usufruct in Roman, French and German law. Comparative legal research
Usufruct is considered to be a truly universal mean of using someone else's thing by agreement with its owner. The institution of usufruct, thus, allows the user, without buying a thing to use all (or some) of its advantages (or fruits) without taking any responsibility for it. In the course of its historical development (and in particular under the impact of Germanisation of this institution) usufruct (its structure, purpose, social functions and, what is even more important, its place in the system of modern legal institutions)underwent considerable changes.To answer the question what particular transformations usufruct has suffered the author analyzed in a comparative way its legal constructions and doctrinal interpretations (social and economic conceptions) in Roman, French, and German law. The article defines the regularities in forming an institution of usufruct in the Roman-Germanic legal family.