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Comparative overview analyzes usufruct regulation in European legal systems, suggesting improvements for Macedonian law.
Usufruct is a form of personal servitude that grants its holder the right to use another person's property fully. It is a real right (right in rem) that originated in Roman law and has since been adopted and integrated into civil codes and property laws across Europe during the reception of Roman law. The right of usufruct has remained relevant and continues to play an important role in modern property law. This paper aims to provide a comparative overview of how usufruct is regulated within the legal systems of European countries, highlighting its main characteristics and shared features. The analysis will focus on the regulation of the usufruct right in Macedonian property law and explore potential improvements to facilitate its practical application.
Tina Pržeska (2026) studied this question.
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