Legal Types of Unilateral Termination of Ownership and Other Property Rights by the State in Russian and Other States

The forced termination by the state of ownership of private property at the present stage of its development has been transformed to such an extent that each of the elements of this institution has undergone changes. As a result, nationalization and expropriation can be considered as legal synonyms, which differ from confiscation only in the absence of a counter‑representation within the latter; in that they are not a sanction for unlawful and unscrupulous behavior, and from requisition in that the basis for their application is not an emergency situation. This article analyzes the antinomies of the development of the institution of nationalization in international law, acts of legislation on the expropriation of property in South Africa and Brazil. The South African Expropriation Act No. 13 of 2024 entered into force in 2025, i. e. it is the most up‑to‑date regulatory act regulating the forced termination by the state of ownership of private assets. The legal regulation of similar legal relations in Brazil, on the contrary, is based on a legal act adopted more than 80 years ago and, despite numerous changes, has retained the features of the pre‑war approach to regulation. The article also evaluates the norms of the Civil Code of the Russian Federation on nationalization, their role in the modern procedure for the compulsory termination by the state of the real (property rights) of other persons in relation to the object of civil rights, and makes suggestions for changing their position in the system of legal regulation.