Concept and Models of Notarial System in the Law of Russia, France, Spain, and England

This article presents a specific analysis of the legal concept of notarial system and the models thereof in Russia, France, Spain and England. Even though the issues of the concept and models of notarial systems have been repeatedly raised in legal doctrine, the consensus has not been reached yet. The authors of the article carry out a comparative legal analysis of the concept of notarial systems and the models thereof in Russia, France, Spain and England in order to identify the existing similarities and differences in the legal regulation of notarial systems.