A comparative study on family poroperty regimes.

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In English law, rules as to which family property belongs to which member of a couple and as to how those items are divided among them when they break down are criticized as ambiguous and unpredictable. On the contrary, French law has two distinct default regimes (regimes primaires), communaute for a married couple and separation de biens for those in Pacte civil de solidalite. Both regimes are theoretically clear and used in different contexts, probably reflecting the difference of supposed intimacy among the members of the two types of couple . Regimes matrimoniaux in the Fench system are worth a more serious study here in Japan.